Statement of Consistency and Planning Report
In respect of
Proposed Student Accommodation Development at The Former Victor Motors Site, Goatstown Road,
Dublin 14
Prepared for
Orchid Residential Ltd.
by
John Spain Associates
September 2020
39 Fitzwilliam Place, Dublin 2 Telephone: (01) 662 5803 E-mail [email protected] September 2020 Statement of Consistency
TABLE OF CONTENTS
1.0 INTRODUCTION ...... 1 2.0 DEVELOPMENT DESCRIPTION...... 4 3.0 NATIONAL AND REGIONAL PLANNING POLICY...... 8 4.0 LOCAL PLANNING POLICY ...... 10 5.0 APPROPRIATE ASSESSMENT ...... 34 6.0 CONCLUSIONS ...... 50 APPENDIX 1
APPENDIX 2
LIST OF FIGURES
Figure 1 – Overall Site Layout ...... 2 Figure 2 - Extract from map within the Urban Design Statement prepared by Reddy Architecture 15 Figure 3 - Section showing the Goatstown Rd frontage of the site ...... 16 Figure 4 - View from the subject site to the brick elevation of Trimbleston on the northern boundary of the site ...... 17 Figure 5 - Design evolution diagrams showing the break and built form and massing and built form of the building ...... 19 Figure 6 – Urban Design Manual 12 criteria...... 24 Figure 7 - Distances from the site to neighbouring development ...... 25 Figure 8 - Core Strategy Map ...... 35 Figure 9 – Land Use Zoning ...... 41 LIST OF TABLES
Table 4.1 – Evaluation of the proposed development in terms of relevant county plan development management policies for housing ...... 36 Table 4.2 – Evaluation of the proposed development in terms of relevant Community Policies 37 Table 4.3– Evaluation of the proposed development in terms of relevant Transport Policies ... 38 Table 4.4– Evaluation of the proposed development in terms of relevant Sustainability Policies ...... 39 Table 4.5– Evaluation of the proposed development in terms of relevant Design Objectives ... 40 Table 4.6 - Evaluation of the proposed development in terms of the LAP’s relevant objectives for population and housing ...... 41 Table 4.7– Evaluation of the proposed development in terms of the LAP’s overall Sustainability ...... 45 Table 4.8– Evaluation of the proposed development in terms of the LAP’s overall Transport and Service Infrastructure ...... 46 Table 4.9– Evaluation of the proposed development in terms of the LAP’s relevant objectives for urban design ...... 47
John Spain Associates Planning & Development Consultants ii September 2020 Statement of Consistency
1.0 INTRODUCTION AND SITE DESCRIPTION
1.1 On behalf of the applicant, Orchid Residential Limited, this Statement of Consistency with Planning Policy has been prepared to accompany this planning application to An Bord Pleanála in relation to a proposed strategic housing development at the car sales premises currently known as Vector Motors (formerly known as the Victor Motors), Goatstown Road, Dublin 14.
1.2 In summary, the proposal will comprise a purpose-built student accommodation scheme of 239 no. student bed spaces and associated amenity space across 3 no. blocks ranging from 4 no. storeys to 6 no. storeys. The development includes internal and external amenity spaces in the form of an external courtyard, ground floor lounge area and study spaces and 2 no. roof gardens, all at a highly accessible location which benefits from proximity to University College Dublin (UDC), c. 800 metres west of the site.
1.3 UCD is the second largest university in Ireland; with c. 33,285 students studying on its 133-hectare grounds. Students attend from all over the country and abroad as UCD is ranked within the top 1% of higher education institutions internationally.
1.4 In addition to the variety of courses provided at undergraduate and postgraduate levels, UCD houses over 120 sports clubs and societies, woodland and sports pitches, gyms, multiple student centres and an extensive range of amenities for its students.
1.5 The percentage of students living in rented private accommodation has been declining from 37% in 2013 to 23% in 2016. This is due to the additional provision of purpose built student accommodation provided. The subject proposed accommodation benefits from its close proximity to UCD, reducing commuting times and allowing students to better utilise the range of facilities provided in both UCD and within the proposed accommodation. It has been shown that students in these types of student accommodation spend 25-30% more time engaged in extra-curricular activities within the college.
1.6 This planning report and consistency with planning policy statement, prepared by John Spain Associates, demonstrates that the proposal is consistent with the relevant national planning policy, guidelines issued under Section 28 of the Planning and Development Act 2000 (as amended), and with local planning policy other than in relation to height (and Part V) as addressed in the Statement of Material Contravention. It should be read in conjunction with the accompanying detailed documentation prepared by Reddy Architecture and Urbanism, Ronan MacDiarmada Landscape Architects and Barrett Mahony Consulting Engineers and other specialist consultants.
1.7 For details of consistency with the quantitative standards for student accommodation and the Dun Laoghaire Rathdown County Development Plan 2016-2022 please refer to the Housing Quality Assessment Schedule prepared by Reddy Architecture and Urbanism.
1.8 This application is accompanied by a comprehensive range of documentation which specifically seeks to address the requirements of the Planning and Development (Housing) and Residential Tenancies Act 2016, the Planning and Development (Strategic Housing Development) Regulations 2017, and items raised by the Planning Authority during pre-application discussions and the relevant sections of the Dun Laoghaire Rathdown County Development Plan 2016-2022 as well as the Goatstown Local Area Plan 2012.
John Spain Associates Planning & Development Consultants 1 September 2020 Statement of Consistency
Figure 1 – Overall Site Layout
Source: Reddy Architects
Site Description
1.9 The subject site is located on Goatstown Road, Dublin 14. The site exists at present as a car showroom and associated car park. The site accommodates a part 1 part 2 storey, flat roofed, car showroom building located in the north-eastern corner of the site. The remainder of the site is tarmacked and provides parking and display spaces for car sales. There is no landscaping or planting on the site.
1.10 The site is typically well lit at night for security reasons. The boundary of the site comprises block and stone walls to the east and south respectively. Screen planting existing on the adjoining sites on the opposite side of the walls. A low stone clad wall with fence above provides the boundary line to the north adjacent to the Trimbleston scheme. Three vehicle access points are currently available to the site from Goatstown Road.
1.11 The site extends to approximately 0.39 hectares and is under ownership of the applicant. A small portion of the site extends into the public domain of Dun Laoghaire Rathdown County Council where service connection works are required. A letter of owners consent accompanies the application from the Council with respect to these works.
Surrounding Area
1.12 The site is bound by residential buildings to the north and east with a two storey neighbourhood centre located adjacent to the southern boundary of the site. The
John Spain Associates Planning & Development Consultants 2 September 2020 Statement of Consistency
neighbourhood centre comprises ground floor retail spaces, a café, bike repair shop and clothing shop. The upper level comprises 2 residential apartments (nos. 4 and 8 Willowfield Park), office space and a real estate office.
1.13 Adjoining development to the north comprises a 5 no. storey apartment building known as Trimbleston. The Trimbleston development further extends to the east of the site including two and three storey houses and duplex units.
1.14 There are a variety of public transport options available to visitors and residents at the proposed site. There are pedestrian routes, bus routes, cycling paths, and Luas facilities within reach of the development, providing significant connectivity to major destinations such as UCD, Dundrum Shopping Centre, and the City Centre area. The site is within or the equivalent of a 13minute walk (6 minute cycle) of the UCD campus. A cycle lane (which is currently being upgraded by the Council) directly connects the site and UCD campus.
1.15 The site is served directly by the no. 11 Bus route operated by Dublin Bus (a stop is located outside Trimbleston c.10m from the site). This connects the proposed student residence to the city centre, as well as St Patricks College Drumcondra, and DCU. The no. 17 bus route operated by Go-Ahead serves UCD from Roebuck Road, which also provides connections to Rialto and Blackrock. The Coombe Maternity Hospital in Rialto is a UCD teaching hospital.
1.16 The Green Line Luas has two stops within walking and cycling distance of the development; Dundrum and Windy Arbour. These provide access across the north and south of the city, in particular TCD and the city centre, the Sandyford Business District, and the Grangegorman campus of TUD in the north of the city.
1.17 Marked cycle lanes are provided on the Goatstown Road, Roebuck Road, Fosters Avenue, and the N11, allowing for safe cycle access to the main entrances to UCD, as well as to the City Centre and other points of interest such as St. Vincent’s Hospital, a UCD teaching hospital.
1.18 In conclusion, the site is well served by public transport links, and major points of interest are within walking and cycling reach, giving a wide variety of transportation alternatives to car usage for residents and guests of the proposed development, in line with DLRCCs aims to promote sustainable transport within the region.
John Spain Associates Planning & Development Consultants 3 September 2020 Statement of Consistency
2.0 DEVELOPMENT DESCRIPTION
2.1 The Site Layout Plan (figure 1) prepared by Reddy Architecture and Urbanism shows the overall layout in context.
Residential Development
2.2 Demolition of the existing part one part two storey car sales building and associated car park on site and construction of a purpose-built student accommodation scheme (PBSA) comprising 239 no. bed spaces, indoor and outdoor student amenity space and site wide landscaping is proposed.
2.3 The scheme will provide individual ensuite study bedroom accommodation, in studios and clustered groupings, generally of 5-8 bedrooms with associated shared living / kitchen / dining areas, providing a model of high-quality student accommodation.
Amenity Space
2.4 Amenity space is provided in a variety of internal and external forms for both passive and active use. External amenity space within the development amounts to 1,554 sqm. This is comprised of a large central courtyard within the development and two roof garden spaces. These spaces provide green space within the development for a communal meeting point and restful space.
2.5 Internal amenity space (507sqm) is divided into study spaces, a laundry and a lounge with a communal kitchen. This provides students with quiet study areas, external to their private rooms, as well as useful amenities such as laundry facilities and a shared kitchen. This kitchen and lounge area creates an internal meeting area for groups and individuals, similar to the roof gardens, while the study spaces allow for education- based meetings for study sessions or group work.
2.6 In addition, UCD is located within a 13 minute walk of the development and provides students with a range of additional facilities such as restaurants, games rooms, a gym, libraries and sports pitches.
Car Parking and Cycle Parking Provision
2.7 A nominal parking provision is proposed onsite including 2 no. disabled car parking spaces and 4 no. set down spaces at the front of the site. A total of 188 no. visitor and resident cycle spaces are provided as part of the scheme. These are provided in two ground floor, covered and secure parking areas in the form of a visitor parking area (Sheffield stands) to the front of the site and a residential area (stacked spaces) within the central courtyard.
Annual Use
2.8 The proposed development will be used for student accommodation only during the academic year and student accommodation and/or tourist/visitor accommodation outside this time.
2.9 It is noted that the Department of Housing, Planning, Community and Local Government Circular PL 8/2016 on ‘Identifying Planning Measures to Enhance Housing Supply’ encourages the use of student accommodation developments for non-student related uses during the non-academic year. It is stated that:
John Spain Associates Planning & Development Consultants 4 September 2020 Statement of Consistency
“A flexible approach should be applied in respect of any planning conditions related to use/occupation of student accommodation. Such an approach would recognise the need to establish a steady rental income for such student accommodation throughout the year in order to ensure the deliverability of development projects from a funding point of view and recognise that student accommodation complexes can play an important role in providing affordable accommodation for tourists and visitors in major urban areas during peak summer demand periods.
Therefore, planning authorities should aim to avoid making permissions for student accommodation complexes subject to restrictions on alternative summer or holiday uses, while at the same time ensuring that student accommodation is:
- not used for residential accommodation of a permanent nature; - safeguarded for use by students and other persons related to the HEI during the academic year; and - capable of being used for legitimate occupation by other persons/groups during holidays periods, when not required for student accommodation purposes”.
2.10 The proposed development has been designed to be capable of being used for short term tourist related use during the non-academic year. As indicated in the Circular, the potential for student related uses (e.g. visiting language schools, etc.) and non-student related uses during the non-academic year is an important component of student accommodation schemes to ensure their commercial viability. It is also important to ensure activity in the area and guard against anti-social behaviour due to an absence of passive surveillance which would decrease outside of the academic year.
2.11 In this regard Section 13 (d) of the Planning & Development (Housing) & Residential Tenancies Act 2016 defines student accommodation as:
a) A building or part thereof used or to be used to accommodate students whether or not provided by a relevant provider (within the meaning of Qualifications and Quality Assurance (Education & Training Act 2012), and that is not for use – i) As a permanent residential accommodation, or ii) As a hotel, hostel, apart-hotel or similar type accommodation, and b) Includes residential accommodation that is used as tourist or visitor accommodation but only if it is so used outside of academic term times.
2.12 Any non-student related use outside the academic year will be managed in the same manner as the student use. The measures set out in the enclosed Management Plan by Fresh Property Group will apply to any non-student use outside the academic year. The Plan provides additional detail on the effective operation of the student accommodation outside academic term time.
Traffic
2.13 It is anticipated that a low number of trips will be generated by the proposed use on a daily basis, ensuring a net decrease in vehicular movements in comparison to the site’s existing use. At present, a number of staff cars, customers and delivery vehicles access the site daily, associated with the operation of the car sales business.
2.14 A set down / pick-up area is included within the site which will be utilised primarily at the beginning and end of university terms, as well as providing access for the disabled and service vehicles. An area for vehicular turning and access has been identified on the accompanying architectural drawings.
John Spain Associates Planning & Development Consultants 5 September 2020 Statement of Consistency
2.15 Outside of approximately weekly access by service vehicles, a low number of movements to and from the site are anticipated. Visits to the site by service and refuse collection vehicles will be arranged outside of peak student movement periods, such as during the afternoon. This will improve the environment for adjacent residents and reduction noise and pollution in the area, having a positive impact on surroundings.
Materials and Finishes
2.16 A variety of materials are proposed within the development to provide visual interest and to create a distinct sense of place. Brown brick and textured brick will be the predominant material uses on the elevations with aluminium framed and panelled windows. Glazing will be used throughout the development and particularly focused around the ground floor of the building, providing a visible connection to Goatstown Road. Metal cladding is used to frame the pop out elements of the building fronting Goatstown Road, articulating and framing the façade. This design response is introduced to reflect the curve of the building.
2.17 This proposed brickwork design has been used successfully in other schemes to date and the overall palette and finishing materials have been selected to complement existing dwellings to the north. The design rationale is explained in further detailed within the Urban Design Report prepared by Reddy Architecture and Urbanism, which accompanies this submission.
Access
2.18 Access to the site is proposed via one-way system into the site. Vehicles will enter the site via Goatstown Road and leave the site in a forward manner via the adjoining exit. Turning circles for HRV’s to accommodate servicing of the site are shown on the civil engineering drawings prepared by Barrett Mahony Consulting Engineers.
Sustainability / Energy
2.19 An energy statement has been prepared by Ronan Meally Engineering. The report confirms that the proposed development will comply with Part L 2017 regulations for student accommodation. An ESB substation and switch room are located east of the main courtyard and are accessible to service vehicles as required.
Noise
2.20 An inward noise assessment has been undertaken by RSK Ireland Limited in order to predict the glazing type requirements for compliance with relevant internal noise limits. The assessment has demonstrated that the desired intrusive noise levels can be achieved using a high performing acoustic double-glazed unit comprising laminated glass incorporating thicker glazed panes than standard double glazing on windows fronting Goatstown Road whilst a double-glazed configuration with slightly thicker glass panes than standard double glazing can be used on all other elevations.
Archaeological Assessment
2.21 A Desktop Archaeological Assessment has been prepared by IAC Archaeology which accompanies this planning application. The report concludes that;
‘There are no known archaeological sites within the site boundary and given the lack of archaeological evidence in the surrounding area, it is unlikely that the proposed development will have an impact on any archaeological deposits.’
John Spain Associates Planning & Development Consultants 6 September 2020 Statement of Consistency
Construction & Waste Management
2.22 An Outline Construction and Environmental Management Plan has been prepared by AWN Consulting and accompanies this application. As set out within the CEMP, the construction of the development will be carried out in accordance with standard methodologies and the ‘Code of Considerate Practice’ with actions to be taken during the construction phase to minimise impacts upon neighbouring properties and the environment outlined.
2.23 The Construction & Demolition Management Plan prepared by AWN Consulting, sets out the measures used in the responsible disposal of waste arising from the construction of the development. The majority of waste generated at the construction phase will be excavated material, with surplus construction materials and cuts also anticipated.
2.24 The Operational Waste Management Plan also prepared by AWN Consulting includes a strategy for the disposal of waste within the operational phase of the development. This is to maximise the quantity of waste recycled by providing sufficient waste recycling infrastructure, waste reduction initiatives and waste collection and waste management information to the residents of the development.
John Spain Associates Planning & Development Consultants 7 September 2020 Statement of Consistency
3.0 PLANNING HISTORY
Ref. D12A/0486
3.1 Permission was granted in 2013 for modification to the front and side facades of existing building to include for raising height of part of existing front facade and for recladding over existing cladding to front elevation and part of side elevation
Ref. D10A/0623/ PL06D238413
3.2 In June 2011, permission was refused by An Bord Pleanála for the refurbishment, extension and change of use of the existing motor sales premises to a neighbourhood shop with ancillary off-licence The proposed extended premises will measure approximately 1,129 square metres (1,029 square metres at ground floor and 100 square metres at first floor level) gross floor space and will have a net retail sales area of 726 square metres.
1. ‘Having regard to the overall size of the proposed retail facility and to the quantum of on-site car parking spaces, it is considered that the proposed development is at tier in the retail hierarchy and of a scale and intensity that is not commensurate with a neighbourhood shop or convenience outlet as provided for in areas subject to the zoning objective A, “to protect and/or improve residential amenity” as set out in the Dun Laoghaire-Rathdown County Development Plan, 2010-2016. The proposed development would, therefore, contravene materially a development plan objective indicated in the said Plan and would be contrary to the proper planning and sustainable development of the area.
2. Having regard to Policy RET8 as set out in the Dun Laoghaire-Rathdown County Development Plan, 2010-2016 (as provided for in section 7.3.7 thereof), which seeks to facilitate provision of local convenience shops in residential areas where there is a clear deficiency in retail provision and where it is accepted that a neighbourhood centre may not be within walking distance, subject to protection of residential amenity and a maximum floor space of 100 square metres, it is considered that provision for a substantial retail facility with a total stated floor area of 1,239 square metres incorporating a net existing and proposed additional sales area of 726 square metres, would be contrary to this policy. The proposed development would, therefore, be contrary to Policy RET8 as set out in the Development Plan and to the proper planning and sustainable development of the area.’
Ref. D07A/0984
3.3 In December 2007, Dun Laoghaire Rathdown Council refused permission for the demolition of the existing structure and construction of a single 3-6 storey block, over part single and part two level basement, comprising 49 apartments (7 no. one bedroom units, 30 no. two bedroom units and 12 no. three bedroom units). The was application was appealed to an Bord Pleanala and refused in September 2008 under Ref. PL06D227350. The reasons for refusal were as follows and are addressed in detail below;
‘Having regard to the Dun Laoghaire-Rathdown County Development Plan 2004- 2011, the Dun Laoghaire-Rathdown County Building Height Strategy (2007) and the Residential Density Guidelines for Planning Authorities issued
John Spain Associates Planning & Development Consultants 8 September 2020 Statement of Consistency
by the Department of the Environment, Heritage and Local Government in September, 1999, it is considered that the proposed development of 48 apartments (as amended) ranging in height from four to six storeys (drawing number P-S-EL-00 Rev A), over two levels of basement car parking on this restricted site, would constitute overdevelopment of the site and, by reason of its height, scale, mass and bulk relative to adjoining buildings and structures and its proximity to the boundaries of the site, would result in a substandard quality of open space within the site due to the effects of overshadowing, be visually obtrusive, particularly when viewed from the south and east along the Goatstown Road and would depreciate the value of property in the vicinity. The proposed development would, therefore, be contrary to the proper planning and sustainable development of the area.’
3.4 Comment: It is noted that the above decision was issued prior to the publication of the Urban Development and Building Height Guidelines (December 2018); National Planning Framework (2018); Rebuilding Ireland – Action Plan for Housing and Homelessness (2016); Regional Economic and Spatial Strategy for the East and Midlands Region 2019. As outlined in detail in the following sections of this report, national policy advocates for regeneration and redevelopment of brownfield sites on in suitable locations (such as the subject site). A detailed assessment process is outlined within SPPR 3 of the Urban Development and Building Height Guidelines where additional height is proposed above the Local Policy requirements. The accompanying Statement of Material Contravention provides a detailed assessment in this justifying the subject proposal.
3.5 The Urban Design Statement prepared by Reddy Architecture details the emerging context of the surrounding area and provides a rationale for the proposed built form. Careful consideration has been given to the treatment of the front elevation of the site with the massing articulated and formulated to respect the curvature of the site. Due to the curved nature of the site, the scheme is only partially visible when viewed from the north on Goatsown Road looking south. The proposed brick finishing complements the adjoining Trimbleston scheme. Similarly, the development steps towards the south and south-east of the site, mindful of the adjoining built-form and topography of the site.
3.6 High-quality landscaping and an improved interface with the public domain will result in an active ground floor and frontage to Goatstown Road. The proposed landscaping will complement the proposed brick finishings, providing a significant improvement in the visual quality of the site when compared to the current use.
3.7 The proposed scheme as demonstrated below and within the accompanying reports and plans accords with national policy and provides a high-quality and well designed built form of suitable scale for the receiving environment.
Ref. D04A/0828
3.8 In February 2005, Dun Laoghaire Rathdown Council granted permission for the demolition of the existing structure and construction of a 3, 4 and 5 apartment block comprised of 30 apartments (2 no.1 bedroom, 28 no. 2 bedroom), 4 duplex units (1 no. 2-bedroom unit and 3 no. 3 bedroom units) and 50 car parking spaces at basement level. There were 18 conditions attached to this grant.
John Spain Associates Planning & Development Consultants 9 September 2020 Statement of Consistency
4.0 CONSISTENCY WITH NATIONAL AND REGIONAL PLANNING POLICY
4.1 The key provisions of national (including relevant Section 28 guidelines) and regional planning policy as it relates to the proposed development is set out in the following sections. The key policy and guidance documents of relevance to the proposed development are as follows:
• National Planning Framework (2018); • Rebuilding Ireland – Action Plan for Housing and Homelessness (2016); • Regional Economic and Spatial Strategy for the East and Midlands Region 2019; • Urban Development and Building Height Guidelines (December 2018); • Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), and the accompanying Urban Design Manual; • The Planning System and Flood Risk Management (2009); • Draft Water Service Guidelines for Planning Authorities (2018); • Guidelines on Residential Developments for 3rd Level Students (2005); • National Student Accommodation Strategy – Rebuilding Ireland (2017). • Transport strategy for the Greater Dublin Area 2016 – 2035; • Smarter Travel – sustainable Transport Future: A New Transport Policy for Ireland 2009-2015 National Planning Framework
4.2 The National Planning Framework (NPF) is the Government’s plan to cater for the extra one million people that will be living in Ireland, the additional two thirds of a million people working in Ireland and the half a million extra homes needed in Ireland by 2040.
4.3 As a strategic development framework, ‘Project Ireland 2040’ sets the long-term context for our country’s physical development and associated progress in economic, social and environmental terms and in an island, European and global context.
National Strategic Outcomes
4.4 The NPF states that carefully managing the sustainable growth of compact cities, towns and villages will add value and create more attractive places in which people can live and work. Section 2.6 of the NPF seeks to provide compact and sustainable growth.
4.5 Chapter 4 of the National Planning Framework seeks to make urban places stronger “to enhance people’s experience of living and working in and visiting urban places in Ireland.” The following is outlined:-
4.6 National Policy Objective 3a of the NPF states that it is a national policy objective to “deliver at least 40% of all new homes nationally within the built up envelope of existing urban settlements”.
4.7 National Policy Objective 4 states ‘ensure the creation of attractive, liveable, well designed, high quality urban places that are home to diverse and integrated communities that enjoy a high quality of life and well-being’.
John Spain Associates Planning & Development Consultants 10 September 2020 Statement of Consistency
4.8 National Policy Objective 13 states ‘In urban areas, planning and related standards, including in particular building height and car parking will be based on performance criteria that seek to achieve well-designed high-quality outcomes in order to achieve targeted growth. These standards will be subject to a range of tolerance that enables alternative solutions to be proposed to achieve stated outcomes, provided public safety is not compromised and the environment is suitably protected.’
4.9 National Policy Objective 33 – ‘Prioritise the provision of new homes at locations that can support sustainable development and at an appropriate scale of provision relative to location.’
4.10 National Policy Objective 34 – ‘Support the provision of lifetime adaptable homes that can accommodate the changing needs of a household over time.’
4.11 National Policy Objective 35 – ‘Increase residential density in settlements, through a range of measures including reductions in vacancy, reuse of existing buildings, infill development schemes, area or site-based regeneration and increased building heights.’
Evaluation of Consistency
4.12 The proposed development accords with the National Planning Framework (2018) (NPF), in particular with its principles of compact growth and the reinforcement of the country’s existing urban structure at all levels. Where housing policy is concerned, the proposed development accords with the NPF’s core principles for housing delivery – in particular that the location of new housing be prioritised in existing settlements.
4.13 In accordance with the NPF’s strategy of compact growth, it is proposed to develop student housing within the existing built-up area of Goatstown, within an infill site.
4.14 In accordance with National Policy Objective 33, new homes will be provided at a sustainable location, with access to existing services and facilities, including UCD Belfield Campus, the Green Luas line within 1.3km of the site and the no. 11 bus stop 10 metres from the site. In accordance with National Policy Objective 35, the proposal will increase residential density within an existing settlement.
Rebuilding Ireland – Action Plan for Housing and Homelessness
4.15 Rebuilding Ireland was launched in 2016 with the objective to double the annual level of residential construction to 25,000 homes and deliver 47,000 units of social housing in the period to 2021, while at the same time making the best use of the existing stock and laying the foundation for a more vibrant and responsive private rented sector.
4.16 Rebuilding Ireland is set around 5 no. pillars of proposed actions summarised as follows;
Pillar 1 – Address Homelessness: Provide early solutions to address the unacceptable level of families in emergency accommodation; deliver inter-agency supports for people who are currently homeless, with a particular emphasis on minimising the incidence of rough sleeping, and enhance State supports to keep people in their own homes.
John Spain Associates Planning & Development Consultants 11 September 2020 Statement of Consistency
Pillar 2 – Accelerate Social Housing: Increase the level and speed of delivery of social housing and other State – supported housing
Pillar 3 – Build More Homes: Increase the output of private housing to meet demand at affordable prices. Pillar 4 – Improve the Rental Sector: Address the obstacles to greater private rented sector delivery, to improve the supply of units at affordable rents.
Pillar 5 – Utilise Existing Housing: Ensure that existing housing stock is used to the maximum degree possible – focusing on measures to use vacant stock to renew urban and rural areas.
Evaluation of Consistency
4.17 The proposed development provides purpose built student housing which reduces the pressure on the private rental market by proving more appropriate housing for students.
4.18 The proposal will deliver much needed student housing within the Metropolitan Area of the Greater Dublin Area in accordance with the aims of Rebuilding Ireland, and in particular Pillar 3, which seeks to build more homes – “to increase the output of private housing to meet demand at affordable prices.”
4.19 The additional 239 no. student bed spaces will provide for managed student accommodation which will free up the pressure on the existing rental market in the area thus making the most of the existing housing stock to cater for much needed rental accommodation.
Eastern and Midlands Regional Authority Regional Economic and Spatial Strategy 2019
4.20 The Regional Economic and Spatial Strategy (RSES) notes that the preferred spatial strategy for the Eastern and Midlands is the consolidation of Dublin plus the Regional Growth Centres of Athlone, Dundalk and Drogheda, supported by planned focussed growth of a limited number of self-sustaining settlements.
4.21 Goatstown is located within the Dublin Metropolitan Area. According to the RSES, the Dublin Metropolitan Area (DMA) is focused on the national capital city, which is the lead settlement in the country, the main gateway into the nation and the largest economic contributor in the state noting that Dublin leads the settlement hierarchy for not only the Region but also the state, with no other comparable settlement within the urban structure.
4.22 Growth enablers for the Dublin metropolitan area include;
• To achieve growth of 1.4 million people in Dublin City and Suburbs and 1.65 million people in the Dublin Metropolitan Area by 2031; • To realise ambitious compact development targets at least 50% of all new homes within or contiguous to the existing built up area in Dublin and at least 30% in other metropolitan settlements;
Metropolitan Area Strategy
John Spain Associates Planning & Development Consultants 12 September 2020 Statement of Consistency
4.23 The Metropolitan Area Strategic Plan (MASP) supports the overall Settlement Strategy as set out in Chapter 5 and sets out an integrated land use and transportation strategy for the sequential development of the metropolitan area focussed on:
• Consolidation of Dublin city and suburbs • Key Towns of Swords, Maynooth and Bray • Planned development of strategic development areas in Donabate, Dunboyne, Leixlip, and Greystones
4.24 The delivery of identified strategic development areas should be facilitated, where practicable, in a sequential manner to promote sustainable compact growth in coordination with the provision of enabling infrastructure and services.
4.25 Dublin City and Suburbs: Support the consolidation and re-intensification of infill, brownfield and underutilised lands with 50% of all new homes to be provided in the existing built up area of Dublin City and Suburbs in tandem with the delivery of key infrastructure to achieve a population of 1.4 million people by 2031.
“For urban-generated development, the development of lands within or contiguous with existing urban areas should be prioritised over development in less accessible locations. Residential development should be carried out sequentially, whereby lands which are, or will be, most accessible by walking, cycling and public transport – including infill and brownfield sites – are prioritised.”
Evaluation of Consistency
4.26 The proposed infill development at Goatstown will consolidate the existing built up area of the Dublin Metropolitan Area and promote sustainable compact growth with access to public transport (Luas line 1.3km from the site and bus links at the subject site) and improves connectivity in the wider area, with UCD within a 14 minute walk of the site.
Urban Development and Building Heights (December 2018)
4.27 The proposed development ranges in height from four to six storeys. Owing to the site’s accessible location to UCD (800m or a 13 minute walk), 10 metres of the 11 bus stop facilitating travel in both directions on Goatstown Road, and 1.3km from the Green Line Luas, an increased building height is considered to be appropriate in the context of Urban Development and Building Height Guidelines 2018. This is discussed in greater detail below and in the accompanying Material Contravention Statement.
4.28 The Urban Development and Building Heights contain SPPR 3 which requires:-
John Spain Associates Planning & Development Consultants 13 September 2020 Statement of Consistency
Evaluation of Consistency
4.29 The following section demonstrates how the proposal complies with the relevant criteria as referred to in SPPR 3 above. We note this section is also addressed in detail within the Material Contravention Statement prepared by John Spain Associates.
The criteria for assessment of developments at the scale of the relevant city / town;
The site is well served by public transport with high capacity, frequent service and good links to other modes of public transport.
4.30 The proposed student accommodation will be highly accessible to UCD by direct cycle lane and pedestrian path and is located adjacent to a bus route (no.11). The DLRCDP also includes an objective for a proposed future quality bus route on Goatstown Road. High frequency, high capacity Luas services are located within walking distance of the site at the Dundrum Luas stop, 1.3km (14 minute walk) from the site. The site is also within close proximity to UCD (800m) and Dundrum town centre (1.5km). See figure 1 below.
John Spain Associates Planning & Development Consultants 14 September 2020 Statement of Consistency
Figure 2 - Extract from map within the Urban Design Statement prepared by Reddy Architecture
Development proposals incorporating increased building height… should successfully integrate into/enhance the character and public realm of the area, having regard to topography, its cultural context, setting of key landmarks, protection of key views. Such development proposals shall undertake a landscape and visual assessment by a suitably qualified practitioner such as a chartered landscape architect.
4.31 The scale of the proposed development is considered to integrate appropriately with its surroundings. The proposed building height takes cognisance of the scale, height and proximity of neighbouring properties and maximises the topography of the site to ensure that the 6 no. storey building is not obtrusive in the surrounding features of the urban environment.
4.32 The existing car sales room and parking area is out of character with surrounding built form. The site contains a flat roofed building, located to the rear of the site, providing no street interaction or urban edge. This is in contrast to the adjoining Trimbleston scheme which fronts the street and addresses the public realm. The proposed development will complement the existing established urban character.
4.33 In terms of the existing topography, the site slopes from south to north in a c. 2m fall across the site. The adjoining neighbourhood centre is therefore higher than the existing surface level of the site. The subject proposal will appear as a three storey development adjacent to the northern boundary due to the topography of the site with the ground level of the neighbourhood centre at 48.580 whilst ground floor level of the proposed scheme will be at 44.590. The fourth floor level of the scheme reaches 57.590 whilst the roof of the adjoining neighbourhood centre reaches 55.883, a difference of 1.7m. It is therefore evident that a suitable transition is provided on this boundary, successfully integrating with existing built form and character of the area.
John Spain Associates Planning & Development Consultants 15 September 2020 Statement of Consistency
4.34 This is demonstrated in the below picture showing the existing pillar of the retaining wall at the southern boundary interface, as viewed from Goatstown Road. A further section prepared by Reddy Architecture (slope shown in a red dashed line) is also included below.
Neighbourhood Centre Building Subject Site
Level difference and retaining wall on southern boundary of the subject site
Figure 2 - Section showing the Goatstown Rd frontage of the site
4.35 The design approach is based on a need to protect the amenities of the surrounding residential developments. Trimbleston to the (north and east) comprises duplexes, terraced housing and apartments which range from 5 storeys (to the north) down to 2- 3 storeys (to the east). The proposed development is in keeping with this density and scale of development, stepping down towards boundary where relevant (rear and south).
4.36 The building design ensures no overlooking to the east with a full brick façade provided on the western elevations, adjacent to the rear boundary of the site. The northern
John Spain Associates Planning & Development Consultants 16 September 2020 Statement of Consistency
boundary fronts a blank façade on the Trimbleston apartment building and accordingly windows have been provided on this elevation. We also note the presence of existing mature screen planting on the adjoining property boundary.
Figure 3 - View from the subject site to the brick elevation of Trimbleston on the northern boundary of the site
4.37 Angled windows are provided on the southern elevation of the building to mitigate any potential for overlooking of the adjoining neighbourhood centre.
4.38 A Landscape Rationale and Drawings prepared by Ronan MacDiarmada and Associates Landscape Architects accompanies this submission and details how the proposed development will successfully integrate with and provide an improved landscaped setting for a site which is currently entirely paved. In this respect the proposal is considered to improve the overall landscaping setting of the neighbourhood.
4.39 A Townscape and Visual Impact Statement, prepared by ParkHood Landscape Architects accompanies the application and concludes that;
‘The proposal would effectively balance and visually correlate to the broad width of Goatstown Road and integrate with the architecture, form, scale and mass of the recent developments to the immediate north at Trimbleston and The Grove making a positive contribution to place-making. It will discernibly step down towards Willowfield Park. The collective will provide enhanced townscape sense of place and legibility while offering variation and relief from the prevailing similar and repetitive building type in Goatstown.’
On larger urban redevelopment sites, proposed developments should make a positive contribution to place-making, incorporating new streets and public spaces, using massing and height to achieve the required densities but with sufficient variety in scale and form to respond to the scale of adjoining developments and create visual interest in the streetscape.
John Spain Associates Planning & Development Consultants 17 September 2020 Statement of Consistency
4.40 The proposed site is not considered to be a ‘large redevelopment site’ being c. 0.39ha. Notwithstanding, the scheme has a clear identity, being physically separate from adjoining development. Access to the site is clearly identifiable to the average passer by with a concierge located at the front of the site at ground level. A clear pedestrian path is provided to this point, from Goatstown Road.
4.41 The height of the apartment blocks will signal the location of the site while providing passive surveillance of the street. The proposed development will contribute to the creation of a sense of place by the creation of high-quality landscaping which will serve to enhance the experience of residents and visitors. Lower heights are proposed where existing dwellings are closest to the site. The proposed treatment of the site frontage remains open to Goatstown Road, successfully integrating with and improving the existing public realm.
At the scale of district / neighbourhood / street
The proposal responds to its overall natural built environment and makes a positive contribution to the urban neighbourhood and streetscape
4.41.1 It is considered that the proposal introduces a high-quality development at an underutilised area of land within a suburban context which is zoned for residential development. The sensitive design and scale of development is considered to make a positive contribution to the urban neighbourhood through the re-establishment of a building line and streetscape. As detailed within the accompanying Photomontages and Visual Impact Assessment, the proposal visually integrates successfully with the surrounding suburban landscape. The proposed presents a significant improvement on the site when compared to the existing industrial use of the site which presents a gap in the building line and is inconsistent with the surrounding land uses.
The proposal is not monolithic and avoids long, uninterrupted walls of building in the form of perimeter blocks or slab blocks with materials / building fabric well considered
4.42 The proposal specifically has taken account of the need to break up the mass of the building, including articulation and pop out elements on the Goatstown Road façade. The proposals incorporate a brick finish, with extensive glazed elements, iodised window frames and high-quality external finishes and paving, in combination with soft landscaping.
John Spain Associates Planning & Development Consultants 18 September 2020 Statement of Consistency
Figure 4 - Design evolution diagrams showing the break and built form and massing and built form of the building
Source: Reddy Architecture
The proposal enhances the urban design context for public spaces and key thoroughfares and inland waterway/ marine frontage, thereby enabling additional height in development form to be favourably considered in terms of enhancing a sense of scale and enclosure while being in line with the requirements of “The Planning System and Flood Risk Management – Guidelines for Planning Authorities” (2009).
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4.43 As noted above, the proposal introduces a development which is compatible with its land use zoning and adjacent development. The scheme will contribute to the creation of a sense of place translated through high quality landscaping proposals which serve to enhance the experience of residents and visitors.
The proposal makes a positive contribution to the improvement of legibility through the site or wider urban area within which the development is situated and integrates in a cohesive manner.
4.44 The proposed development is logically laid out, having regard to the site’s terrain and the context in which it sits. Due to the nature of the subject brownfield site, adjacent to existing established and privately owned residential uses, the proposed development will provide a more appropriate use on the subject site when compared to its current use as a car sales premises.
At the scale of the site/building
The form, massing and height of proposed developments should be carefully modulated so as to maximise access to natural daylight, ventilation and views and minimise overshadowing and loss of light.
Appropriate and reasonable regard should be taken of quantitative performance approaches to daylight provision outlined in guides like the Building Research Establishment’s ‘Site Layout Planning for Daylight and Sunlight’ (2nd Edition) or BS 8206-2: 2008 – ‘Lighting for Buildings – Part 2: Code of Practice for Daylighting’.
Where a proposal may not be able to fully meet all the requirements of the daylight provisions above, this must be clearly identified and a rationale for any alternative, compensatory design solutions must be set out, in respect of which the planning authority or An Bord Pleanála should apply their discretion, having regard to local factors including specific site constraints and the balancing of that assessment against the desirability of achieving wider planning objectives. Such objectives might include securing comprehensive urban regeneration and or an effective urban design and streetscape solution.
4.45 A Sunlight/Daylight Analysis Report has been prepared by Digital Dimensions and accompanies the application. The sunlight / daylight analysis assessed the level of light access within rear gardens and windows of neighbouring residential properties, particularly to the south and east of the site at Willowfield Road and Trimbleston. The report concludes there will be negligible impact on adjoining properties with the proposal complying with BRE recommendations (available light is not reduced below 0.8 times the former value). The proposed development performs well in regard to daylight and sunlight within the site.
Specific Assessments
4.46 SPPR 3 also states that specific assessments may be required to ‘support developments ‘at some or all of these scales’. The specific assessments are outlined below with a comment included noting how each criteria is addressed, if relevant to the subject proposal;
• Specific impact assessment of the micro-climatic effects such as down-draft. Such assessments shall include measures to avoid/ mitigate such micro-
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climatic effects and, where appropriate, shall include an assessment of the cumulative micro-climatic effects where taller buildings are clustered.
4.47 Comment: A wind micro climate assessment has not been prepared as the building is below 30m in height and the proposed tree planting will mitigate any minor downdraft conditions. The proposed development is not considered to comprise tall buildings. The proposal is consistent with the adjoining 5 storey development to the north stepping to 4 storeys to the southern boundary. The building ranges in height from 4 storeys to 6 storeys and is not considered to be of such a scale that will impact the micro-climate.
4.48 A Sustainable Energy Report is also submitted with the proposal. Overall, the proposal will have a positive impact on climate change, contributing a sustainable building design, on a brownfield site in close proximity to public transport.
• In development locations in proximity to sensitive bird and / or bat areas, proposed developments need to consider the potential interaction of the building location, building materials and artificial lighting to impact flight lines and / or collision.
4.49 Comment: The subject site is not in proximity to such a location. Notwithstanding, the application is accompanied by a Bat Assessment Prepared by Wildlife Surveys and concludes there are no bat roosts on the site. The report concludes;
‘It is predicted that there will be no impact upon bats within the area of long-term to permanent duration.
4.50 In relation to sensitive bird areas, the AA Screening report includes an ecological assessment of the site from this perspective and concludes;
‘The subject site is located in a heavily urbanised environment close to significant noise and artificial light sources such as roads. This development cannot contribute to potential disturbance impacts to species or habitats of for which Natura 2000 areas have been designated.’
4.51 This report and the accompanying Ecological Impact Assessment demonstrate that the proposed building heights do not have the potential to adversely impact on the biodiversity of the area. As outlined in the AA Screening, the development will not increase disturbance effects to birds in Dublin Bay given its distance from these sensitive areas. The subject site and adjacent built-up/urban lands are not suitable for wetland birds and so cannot contribute to any ex-situ impacts.
• An assessment that the proposal allows for the retention of important telecommunication channels, such as microwave links.
4.52 Comment: The subject site currently does not contain any telecommunication antennae or towers and is not of a significant height (less than 30m) that would impact on telecommunication channels. Notwithstanding, Ronan Meally Consulting Engineers have reviewed the proposed from this perspective
‘In the unlikely event that the development has any impact this will be realised during the construction period. At this stage we will engage with telecommunication companies to re-align their microwave links to new hop sites to mitigate any issues.’
John Spain Associates Planning & Development Consultants 21 September 2020 Statement of Consistency
• An assessment that the proposal maintains safe air navigation.
Comment: The proposed buildings are not of such a height as to justify any specific assessment in relation to air navigation safety. The Dun Laoghaire Rathdown CDP does not include any policies or objectives in relation to air navigation and the site is removed from any airports. A Sunlight/Daylight Analysis Report has been prepared by Digital Dimensions and accompanies the application. The sunlight / daylight analysis assessed the level of light access within rear gardens and windows of neighbouring residential properties, primarily to the south and east of the site at Willowfield Road and Trimbleston. The report concludes there will be negligible impact on adjoining properties with the proposal complying with BRE recommendations (available light is not reduced below 0.8 times the former value). The proposed development performs well in regard to daylight and sunlight within the site.
• An urban design statement including, as appropriate, impact on the historic built environment.
4.53 Comment: An Urban Design Statement has been prepared by Reddy Architecture and Urbanism and accompanies the application. The site is not within a nominated conservation area, does not contain a protected structure nor is it in close proximity to an architectural conservation area or protected structure and accordingly a heritage impact assessment is not required.
• Relevant environmental assessment requirements, including SEA, EIA, AA and Ecological Impact Assessment, as appropriate.
4.54 Comment: The application is accompanied by an AA Screening Report, Ecological Impact Assessment and EIA Screening report as required.
4.55 From the above analysis, it is considered that the proposal meets the criteria for higher buildings as set out within the Guidelines on Building Height Guidelines. The site is well placed to absorb a high density development which is appropriately scaled and designed in the context of its urban surroundings, at a highly accessible location and in close proximity to high frequency public transport. The site also benefits from easy access to UCD campus as well as connections to Dundrum and other surrounding areas.
Sustainable Residential Development in Urban Areas (2009)
4.56 The Sustainable Residential Development in Urban Areas (SRD) Guidelines provide guidance on the core principles of urban design when creating places of high quality and distinct identity. The Guidelines recommend that planning authorities should promote high quality design in their policy documents and in their development management process. To assist with this, the Guidelines are accompanied by a Design Manual discussed below which demonstrates how design principles can be applied in the design and layout of new residential developments, at a variety of scales of development and in various settings.
4.57 The role of the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas is to ensure the ‘plan led’ delivery of new development throughout the country.
Evaluation of Consistency
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4.58 The proposed development accords with the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009) and could be best described as a large infill site, having regard to an existing residential development to the north and east of the site, Trimbleston (ABP Ref. PL06D.130581/DLRCC Ref. D04A/0707).
4.59 This development comprises housing and apartments which range from 5 storeys (to the north) down to 2-3 storeys (to the east). The proposed development steps in height as it moves from north to south. In addition, the height of the subject development is reduced towards the south of the site where there are existing 2 no. storey commercial units.
4.60 It is noted the western portion of the lands are located adjacent to a bus route (no.11). The site is also proposed as a future quality bus route, within the development plan. Higher frequency Luas services are located at the Dundrum Luas stop, 1.3km from the site.
4.61 The SRD notes that a balance has to be struck between the reasonable protection of the amenities and privacy of adjoining dwellings, the protection of established character and the need to provide residential infill. Traditionally, Goatstown can be characterised as two storey developments, however this is undergoing change and evolution to provide a degree of consolidation to adhere to a more compact urban form. The Trimbleston development, to the north and east of the site, provides a newer, more high-density style development as a template for the area. The Trimbleston residential development features a mixture of 4-5 storey apartments as well as 2-3 storey houses. These are stepped down from 5 storeys at the north of the site, to 2-3 storeys at the southern point. The proposed development mirrors this, stepping down from 6 storeys to 4, north to south.
4.62 We also note the ongoing redevelopment of the Grove to the north of the site which includes 5 no. storey residential buildings. The area is undergoing change in line with national policy to achieve sustainable development.
4.63 The proposed development conforms to the more detailed guidance within the Guidelines on layout, design and density – by making effective use of the site; making a positive contribution to its surroundings; having a sense of identity and place; providing for effective connectivity, and featuring a design which is guided by the principles of passive surveillance. The proposed development meets the 12 criteria for sustainable residential development contained within the Urban Design Manual (2009), a companion document to the SRD Guidelines, examined below and set out in the Reddy Architects design statement.
4.64 The proposed development reduces car parking numbers providing to disabled parking and set-down spaces only. This allows for a greater emphasis on cycle parking and pedestrian paths.
4.65 The central courtyard is a key example of this; providing links between amenity spaces, the surrounding area and residential units while remaining solely for pedestrians and cyclists. This allows the space to provide real amenity through landscaping, instead of being used as a road or car parking. The layout is considered to be legible, with a clear
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distinction in design, character and treatment between distributor, local and shared surface streets.
4.66 The Guidelines also provide guidance on the core principles of urban design when creating places of high quality and distinct identity. The Guidelines are accompanied by a Design Manual which demonstrates how design principles can be applied in the design and layout of new residential developments, at a variety of scales of development and in various settings.
4.67 The Design Manual sets out a series of 12 criteria which it recommends should be used in the assessment of planning applications and appeals. The 12 criteria are discussed in detail below. This pre-application consultation request is accompanied by a Design Statement, prepared by Reddy Architects, which demonstrates how the proposed development has regard to and has been developed in accordance with best practice in respect to urban design. The Design Statement should be read in conjunction with this Statement of Consistency and Planning Report and with the plans and particulars accompanying this submission.
Urban Design Manual – A Best Practice Guide (2009)
Figure 5 – Urban Design Manual 12 criteria
Source: Urban Design Manual DoEHLG 2009
4.68 The Urban Design Manual is based around 12 criteria that have been drawn up to encapsulate the range of design considerations for residential development based on ‘’a distillation of current policy and guidance and tried and tested principles of good urban design.’’ Compliance with the 12 no. criteria are assessed within the Urban Design Report prepared by Reddy Architecture and summarised as follows:
Context: How does the development respond to its surroundings?
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4.69 The proposed development re-establishes the building line of the streetscape improving the public realm and develops the relationship between the development and its surroundings.
4.70 The existing buildings to the north, south and east have been considered as part of this development. The density and style of development to the north and east of the site has been mirrored in this design through the reduction of height from north to south. The height of the development is reduced towards the south adjacent to the neighbourhood centre.
Figure 6 - Distances from the site to neighbouring development
4.71 The overall layout of the design has been centred around an internal courtyard; this reduces overlooking onto adjacent sites while still allowing for passive surveillance of the courtyard and the road frontage.
4.72 The proposed rear brick gable wall is 14.5m from the windows of the 2 storey Trimbleston dwellings (no. 165). No windows are proposed on this elevation (east). The existing three storey dwellings (157 – 164 Trimbleston) are sited c.28.5m from the windows of the proposed building. These dwellings will overlook the proposed central courtyard which extends to c. 20m at its narrowest point from the rear boundary to the proposed building, providing an improved landscaped setting.
4.73 Windows on the southern elevation have been offset and angled to mitigate any overlooking of the adjoining neighbourhood centre. We also note that the windows of the neighbourhood centre do not directly front the subject site.
Connections: How well is the new neighbourhood / site connected?
4.74 The site location is central to numerous facilities: Goatstown is an urban village but is located within a network of suburbs and centres around the Dun Laoghaire Rathdown Council area. The site itself is within walking distance of UCD and multiple shops and
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restaurants. Dundrum town centre is less than 1.5km from the subject site and provides a wide variety of retail, entertainment and food services.
4.75 The site is also located along a Dublin Bus route and is a 14 minute walk from a Luas stop. This provides access to wider variety of facilities.
Inclusivity: How easily can people use and access the development?
4.76 The proposed development includes units which are suitable for mobility impaired persons, which allows for ease of access. Landscape design and detailing of roads and footpaths provide for movement throughout the development by mobility impaired persons, in compliance with Building Regulations Part M.
4.77 The proposed development will provide pedestrian and cycle routes throughout the site. Disabled car parking spaces and set down spaces are also provided within the development.
Variety: How does the development promote a good mix of activities?
4.78 The proposed amenity spaces are provided in a variety of internal and external uses; for both passive and active use as detailed in the accompanying suite of architectural design reports.
4.79 The external amenity space within the development amounts to 1,554 sqm of space. This is comprised of a large central courtyard within the development and multiple roof garden spaces. These provide green space within the development for a communal meeting point and restful space.
4.80 The internal amenity space provided is divided into study spaces, a laundrette and a lounge with a communal kitchen. This provides students with quiet study areas, external to their private rooms as well as useful amenities such as laundry facilities and a shared kitchen. This kitchen and lounge area creates an internal meeting area for groups and individuals, similar to the roof gardens, while the study spaces allow for education-based meetings for study sessions or group work.
4.81 In addition, UCD is located within 800m of the development and provides it students with a range of additional facilities such as restaurants, a cinema, sports centre, a gym, libraries and sports pitches.
Efficiency: How does the development make appropriate use of resources, including land?
4.82 The proposed layout is well designed so that efficient numbers of bed spaces can be accommodated as well as a high-quality amenity space. Amenity space is located primarily on the ground level for accessibility, with roof gardens creating more green space without under-developing the site.
4.83 A central interior courtyard provides open space and improves connections through the site, while creating an attractive area for rooms to look onto. A reduction in car parking on the site prevents a waste of land on a key site, when public transport and local facilities render car parking unnecessary.
Distinctiveness: How do the proposals create a sense of place?
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4.84 The design of the development is based around a central courtyard: this centres the development with a landscaped communal space, featuring links to the clusters, amenity space and entrance. The amenities are predominantly located on the ground floor of the development; further developing an open, communal courtyard and ground floor with a range of uses.
4.85 The materials used in finishing the development, the range of heights from 4-6 storeys and the breaking of the site into multiple blocks all help to create the feeling of multiple spaces and the creation of a neighbourhood, while still providing the connectivity of a single site.
Layout: How does the proposal create people-friendly streets and spaces?
4.86 The proposed site is designed around pedestrians and cyclists: car parking spaces are limited within the development, instead choosing to utilise the nearby facilities, public transport and include safe, sheltered cycle spaces. As a result, the main space through the development is a courtyard, which connects the three blocks, the bicycle storage and the ground floor amenity spaces.
4.87 The courtyard is a people-focused space at the centre of the development which benefits from landscaping and passive surveillance.
Public Realm: How safe, secure and enjoyable are the public areas?
4.88 The communal areas of this development are predominantly the central courtyard and the rooftop gardens. The central courtyard is landscaped and provides access to multiple areas within the ground floor of the development. In order to ensure security, it is also overlooked by the ground floor amenities and the rooms on the upper floors.
4.89 The roof gardens provide green space and a relaxing atmosphere for the residents of the development. These are kept secure as their access is limited to residents.
4.90 The boundary interface with Goatstown Road will be upgraded to include landscaping and planting. Clear pedestrian access will be provided to the site and the overall interface with the public realm will be greatly improved.
4.91 Due to the ongoing upgrade works outside the site to improve cycle lanes through out Dun Laoghaire Council area, the applicant respectfully requests a condition be included to provide additional planting within the public domain should this be required by Dun Laoghaire Rathdown Council.
Adaptability: How will the buildings cope with change?
4.92 The proposed development provides a range of clusters of accommodation which could be altered, separated or combined if needed. In addition, the range of amenity spaces could be redesigned or updated to meet future needs as required. This is further detailed in the Urban Design Report by Reddy Architecture.
Privacy / Amenity: How do the buildings provide a high quality amenity?
4.93 High quality amenity space is provided in a variety of internal and external uses; for both passive and active use.
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4.94 The external amenity space within the development amounts to 1,554 sqm of space. This is comprised of a large central courtyard and multiple roof garden spaces. These provide green space within the development for a communal meeting point and restful space.
4.95 The internal amenity space provided is divided into study spaces, a laundrette and a lounge with a communal kitchen. This provides students with quiet multi-functional rooms, external to their private rooms as well as useful amenities such as laundry facilities and a shared kitchen. This kitchen and lounge area creates an internal meeting area for groups and individuals, similar to the roof gardens, while the study spaces allow for education-based meetings for study sessions or group work.
Parking: How will the parking be secure and attractive?
4.96 A nominal parking provision for disabled spaces and set down spaces (6 no spaces in total) are provided at the site frontage. This allows for greater cycle parking facilities (188 no. spaces) in covered and secure locations within the central courtyard and adjacent to the western boundary at the north of the site.
Detailed Design: How well thought through is the building and landscape design?
4.97 The proposed design of the development has been subject to a number of pre- application consultations between the design team and the Planning Authority (noted at Appendix 2). The design rationale from an urban design and architectural perspective is explained in the Urban Design Statement prepared by Reddy Architects. The landscape design rationale is set out in the Landscape Design Statement prepared by Ronan MacDiarmada.
Delivering Homes, Sustaining Communities (2007)
4.98 The Department’s policy statement Delivering Homes, Sustaining Communities, Guidance provides the overarching policy framework for an integrated approach to housing and planning. The purpose of these Guidelines is to promote high standards in the design and construction and in the provision of residential and services in new housing schemes.
4.99 They encourage best use of building land and optimal utilisation of services and infrastructure in the provision of new housing; point the way to cost effective options for housing design that go beyond minimum codes and standards; promote higher standards of environmental performance and durability in housing construction; seek to ensure that residents of new housing scheme enjoy the benefits of first-rate living conditions in a healthy, accessible and visually attractive environment; and provide homes and communities that may be easily managed and maintained.
Evaluation of Consistency
4.100 The proposed development has taken regard of this policy in its design and development and is observed to promote a high quality residential scheme which makes optimum use of an area of brownfield, infill land in a strategic location and promotes a sense of community.
Design Manual for Urban Roads and Streets (DMURS) (2013)
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4.101 The Design Manual for Urban Roads and Streets (DMURS), 2013, sets out design guidance and standards for constructing new and reconfiguring existing urban roads and streets in Ireland. It also outlines practical design measures to encourage more sustainable travel patterns in urban areas.
Evaluation of Consistency
4.102 The Civil Engineering Infrastructure Report prepared by BMCE Engineering provides further detail in respect of the consistency of the proposed development with DMURS, which is discussed below also.
4.103 DMURS aims to end the practice of designing streets as traffic corridors, and instead focus on the needs of pedestrians, cyclists, and public transport users. The Manual sets out design guidance and standards for constructing new and reconfiguring existing urban roads and streets in Ireland. Incorporating good planning and design practice and focus on the public realm, it also outlines practical design measures to encourage more sustainable travel patterns in urban areas. The principal design guidance of DMURS has been considered in the design of this development. The proposed development seeks to prioritise pedestrian and cyclists throughout and around the site in accordance with the policies set out in DMURS.
The building design and site layout of the proposed development has had regard to the recommendations of DMURS as it includes proposals for a building fronting onto Goatstown Road and focuses on cycle and pedestrian friendly spaces.
Draft Water Services Guidelines For Planning Authorities 2018
4.104 The Draft Water Services Guidelines for Planning Authorities were published in January 2018 by the DoHPLG, which sets out a clear structure for actively managing the interface between spatial planning and development and water services planning. The Water Services Guidelines for Planning Authorities have been prepared by the Department of Housing, Planning and Local Government in consultation with Irish Water.
4.105 The Guidelines provide best practice guidance in relation to the interface between planning and development functions provided by planning authorities and the delivery of public water services by Irish Water.
4.106 The key aims of the Guidelines are to:
• Provide advice to planning authorities on the operational framework within which Irish Water must operate to deliver water services, • Establish mechanisms for effective engagement between planning authorities and Irish Water across all the relevant functions of planning authorities, and • Set out how the planning system, in setting out a spatial framework for growth and development, will relate to and inform the planning and delivery of water services by Irish Water at a national, regional and local level.
4.107 Section 5 sets out development management guidance in respect of developments. The Draft Guidelines note that applications “should indicate if it is intended to connect to Irish Water’s water supply and / or wastewater networks, whether a pre-connection enquiry has been made to Irish Water and where available a copy of the Confirmation of Feasibility (see 5.4) issued by Irish Water should be included with the application.’
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4.108 The Draft Guidelines state that it is a requirement for Strategic Housing Development applications to contain evidence that Irish Water has confirmed that it is feasible to provide the appropriate service or services and that the relevant water network or networks have the capacity to service the development.
4.109 The Draft Guidelines outline that having regard to the views of Irish Water and having satisfied itself “that there is a reasonable prospect of the constraint(s) being addressed within the lifetime of the permission, a planning authority or An Bord Pleanála (in the case of a SHD application) may approve, inter alia, this aspect of the development, subject to a condition that requires the applicant to enter into a connection agreement (s) with Irish Water to provide for a service connection to the public water supply and / or wastewater collection networks, as appropriate.”
Evaluation of Consistency
4.110 BM Consulting Engineers have consulted with Irish Water on the design of the development and a confirmation of feasibility and Statement of Design Acceptance is included with the application material.
Guidelines for Planning Authorities on ‘The Planning System and Flood Risk Management (November 2009)’
4.111 The Planning System and Flood Risk Management Guidelines were published by the Minister for the Environment, Heritage & Local Government in November 2009 under Section 28 of the Planning & Development Act 2000 (as amended). The Planning system and flood risk management guidelines require the planning system at all levels to avoid development in areas at risk of flooding, particularly floodplains, unless there are proven wider sustainability grounds that justify appropriate development and where the flood risk can be reduced or managed to an acceptable level without increasing flood risk elsewhere; adopt a sequential approach to flood risk management when assessing the location for new development based on avoidance, reduction and mitigation of flood risk; and incorporate flood risk assessment into the process of making decisions on planning applications and planning appeals.
Evaluation of Consistency
4.112 In order to comply with these Guidelines a Site Specific Flood Risk Assessment (SSFRA) has been prepared by BM Consulting Engineers and accompanies the application.
4.113 The SSFRA was prepared to comply with current planning legislation, in particular the recommendations of “The Planning System & Flood Risk Management - Guidelines for Planning Authorities”. The report concludes;
‘It can be concluded that there is no present risk of flooding to the site’
Smarter Travel – A Sustainable Transport Future: A New Transport Policy for Ireland 2009-2020
4.114 The Government has committed in ‘Smarter Travel – A Sustainable Transport Future: A New Transport Policy for Ireland 2009 – 2020’ to reducing the total share of car commuting from 65% to 45%, a rise in non-car trips by 55% and that the total vehicle miles travelled by the car fleet will not increase. The key targets are as follows:
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• Future population employment growths will predominantly take place in sustainable compact forms which reduces the need to travel for employment and services; 500,000 more people will take alternative means to commute to work to the extent that the total share of car commuting will drop from 65% to 45%; • Alternatives such as walking, cycling and public transport will be supported and provided to the extent that these will rise to 55% of total commuter journeys to work; • The total kilometres travelled by the car fleet in 2020 will not increase significantly from current levels; • A reduction will be achieved on the 2005 figure for Greenhouse gas emissions from the transport sector.
Evaluation of Consistency
4.115 Key to the achievement of these targets is better alignment between land-use and transport to minimise travel demand. The subject proposal includes 188 no. bicycle spaces for visitor and resident use. The site is within 800m of UCD Belfield campus and cycling and walking will be encouraged as the main form for transport to and from the university. Thus, the principle of a residential development at an appropriate density which utilises the subject site to its potential in this location would be in accordance with the principles set down in Smarter Travel.
Transport Strategy for the Greater Dublin Area 2016 - 2035
4.116 This strategy has been prepared by the National Transport Authority. The Vision of this strategy is for Dublin to be a competitive, sustainable city-region with a good quality of life for all by 2030.
4.117 The Strategy includes five overarching objectives to achieve the vision which are as follows:
• Build and strengthen communities • Improve economic competitiveness • Improve the built environment • Respect and sustain the natural environment • Reduce personal stress
4.118 The Strategy sets out measures to achieve the vision and objectives for the GDA. These include better integration of land use planning and transportation, consolidating growth in identified centres, providing more intensive development in designated town and district centres and control parking supply.
The strategy builds on previous strategies and investment programmes, and for this reason several major infrastructure schemes that are included in the government’s transport 21 investment framework are included in all of the strategy options
Evaluation of Consistency
4.119 The proposal provides a residential development on an infill, brownfield site adjacent to a direct cycle lane which links the site to UCD campus which will be the main relevant focal point for residents of the scheme. The proposed development is pedestrian and cycle orientated, encouraging sustainable transport modes to and from the site. A small
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parking provision encourages alternate transport methods. The proposal addresses the objectives of the strategy.
National Student Accommodation Strategy – Rebuilding Ireland (2017)
4.120 The first ever National Student Accommodation Strategy (NSAS) for Ireland’s higher education sector was published in July 2017.
4.121 The NSAS notes that Rebuilding Ireland set a target to bring on-stream an additional 21,000 purpose-built student accommodation bed spaces by 2024.
4.122 The NSAS is designed to ensure that there is an increased level of supply of purpose- built student accommodation (PBSA) to reduce the demand for accommodation in the private rental sector by both domestic and international students attending our Higher Education Institutions (HEIs).
4.123 The NSAS highlights that particular measures of success will include full delivery of the following eight key targets which include:
‘Construction of at least an additional 21,000 PBSA bed spaces places by 2024 over the baseline figure of 33,441 PBSA bed spaces which are currently available.’
4.124 The NSAS acknowledges that housing for students is a specific and important segment of the overall housing sector with distinct characteristics and requirements and that “This has a significant related impact on the private rental sector and an increase in the provision of student accommodation is a key priority in addressing the housing crisis.”
4.125 The NSAS notes that the impact of an additional 21,000 student accommodation bed spaces, in addition to an additional 1,500 Digs spaces, will free up at least an additional 5,000 rental units for the wider residential rental sector.
4.126 Based on the data available approximately 18% of full-time students in Ireland are accommodated in PBSA. This figure is low by internationally comparisons with the equivalent figure for the UK published by Higher Education Statistics Agency (HESA) being c. 27%.
Evaluation of Consistency
4.127 The proposed student accommodation and ancillary services will provide much needed purpose built student accommodation located in close proximity to University College Dublin and to other 3rd level colleges which will support the overall objectives of the NSAS of providing additional student accommodation, which is a key priority in addressing the housing crisis.
4.128 The addition of 239 no. purpose built student bed spaces will assist in reaching the 21,000 bed spaces target by 2024. This development aims to create a high quality residential environment in a location central for transport, access to third level education and existing amenity.
4.129 This will reduce the number of students in rental units and digs, instead placing them in units designed for their educational development.
Appropriate Assessment
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4.130 Under Article 6 (3) of the EU Habitat Directive and Regulation 30 of SI no. 94/1997 “European Communities (Natural Habitats) Regulations (1997)” any plan or project which has the potential to significantly impact on the integrity of a Natura 200 site (i.e. SAC or SPA) must be subject to an Appropriate Assessment. This requirement is also detailed under in the Planning and Development Acts (2000 – 2010).
4.131 We refer the Board to the enclosed Appropriate Assessment screening report prepared by Openfield, which concludes that:
“On the basis of the screening exercise carried out above, it was concluded that the possibility of any significant impacts on any European Sites, whether arising from the project itself or in combination with other plans and projects, can be excluded beyond a reasonable scientific doubt on the basis of the best scientific knowledge available. In reaching that conclusion, it was not necessary to consider any measures to avoid or reduce the impact of the proposed development.”
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5.0 LOCAL PLANNING POLICY
5.1 The site is located within the administrative area of Dun Laoghaire Rathdown County Council and is therefore subject to the land use policies and objectives of The Dun Laoghaire Rathdown County Development Plan 2016-2022 (CDP).
5.2 The key provisions of local planning policy relating to the proposed development are set out in the following sections. Reference is made to the following documents:
• The Dun Laoghaire Rathdown County Development Plan 2016-2022; • The Goatstown Local Area Plan 2012. 5.3 An evaluation of the proposed development in terms of the relevant policy or policies is included within each section.
Dun Laoghaire Rathdown County Development Plan (2016-2022)
5.4 Appendix 1 of the Dun Laoghaire Rathdown County Development Plan sets out the main policies and objectives relating to the Dun Laoghaire Rathdown County Development Plan 2016-2022.
Core Strategy
5.5 The central focus of the Core Strategy is on ‘residential development and in ensuring that there is an acceptable equilibrium between the supply of zoned, serviced land for residential development and the projected demand for new housing, over the lifetime of the Plan’.
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Figure 7 - Core Strategy Map
5.6 A key strand of the overall Settlement Strategy focuses on the ‘continued promotion of sustainable development through positively encouraging consolidation and densification of the existing urban/suburban built form – and thereby maximizing efficiencies from already established physical and social infrastructure’.
5.7 The Strategy seeks to focus higher density development in suitable strategic nodes along existing or planned public transport corridors. The subject lands occupy a brownfield site on land located in the northern part of the County, approximately 1.4km east of the major centre of Dundrum and 800m from UCD Belfield Campus which includes numerous services and amenities, particularly suited to the students who will occupy the scheme.
5.8 Section 2 of the County Development Plan contains the Sustainable Communities Strategy. The vision of the Strategy is ‘To develop sustainable and successful communities across the County both through the continuing consolidation and redevelopment of the established built up areas, and the promotion of new, compact mixed–use urban villages optimally located in greenfield areas well served by existing or planned public transport networks and where residents will be within walking distance of supporting social and community infrastructure – including shops, services, employment opportunities, schools and leisure facilities’.
5.9 The Sustainable Communities Strategy notes that one of the two models to be used to accommodate future growth will be ‘Through the continuing promotion of additional infill accommodation in existing town and district centres at public transport nodes, brownfield sites and established residential areas.’
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5.10 The proposed residential development, which provides for 239 no. student bed spaces in close proximity to high quality public transport infrastructure, existing social and community infrastructure and UCD Belfield Campus is considered to be consistent with the vision and strategies outlined above.
Relevant Policies
Table 5.1 – Evaluation of the proposed development in terms of relevant county plan development management policies for housing
Development Management Policy Evaluation
Policy RES2: It is Council policy to facilitate the The proposed development is in line with the implementation and delivery of the Interim Interim Housing Strategy through the provision of Housing Strategy 2016 – 2022. 239 no. new student bed spaces, creating housing for 239 no. students and easing the pressure on the local rental market.
Policy RES3: It is Council policy to promote The proposed development is in keeping with higher residential densities provided that national height guidelines, providing higher proposals ensure a balance between the density development in an established urban reasonable protection of existing residential area on an infill site. amenities and the established character of areas, with the need to provide for sustainable Furthermore, the proposal provides a range of residential development. In promoting more external and internal amenities for the students compact, good quality, higher density forms of within the development. This, in addition to high residential development it is Council policy to quality design and layout provides a development have regard to the policies and objectives in line with the stated objectives. contained in the following Guidelines: The proposal will provide an active frontage to • ‘Sustainable Residential Goatstown Road and a significantly improved Development in Urban Areas’ interface with the existing public domain. (DoEHLG 2009). • ‘Urban Design Manual - A Best Further assessment of the integration of the built Practice Guide’ (DoEHLG 2009). form with the character of the area is included • ‘Quality Housing for Sustainable within the Townscape and Visual Impact Communities’ (DoEHLG 2007). Assessment by Park Hood. • ‘Irish Design Manual for Urban Roads and Streets’ (DTTaS and DoECLG, 2013). • ‘National Climate Change Adaptation Framework - Building Resilience to Climate Change’ (DoECLG, 2013).
Policy RES12: It is Council policy to facilitate The proposed development is located within student accommodation on student campuses 800m of UCD campus and is easily accessible on or in locations which have convenient access to foot or by bike (via direct cycle lanes). In addition, Third Level colleges (particularly by foot, bicycle there are public transport links to other third level and high quality and convenient public transport) education centres nearby via the green line Luas in a manner compatible with surrounding (1.4km) or Dublin bus (10 metres to the nearest residential amenities. stop).
In considering planning applications for student The ‘Guidelines on Residential Developments for accommodation the Council will have regard to Third Level Students’ and its July 2005 Review the ‘Guidelines on Residential Developments for have been addressed in the Response to ABP Third Level Students’ and its July 2005 Review Opinion document prepared by John Spain (particularly in relation to location and design). Associates and within the HQA and Architectural
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Development Management Policy Evaluation
Response to ABP prepared by Reddy Architecture.
Policy RES14: It is Council policy to plan for The above section 4 of this report address in communities in accordance with the aims, depth how the proposed development is in objectives and principles of ‘Sustainable keeping with the principles of ‘Sustainable Residential Development in Urban Areas’ and Residential Development in Urban Areas’ and the the accompanying ‘Urban Design Manual – A accompanying ‘Urban Design Manual – A Best Best Practice Guide’. In all new development Practice Guide’. The site is considered an infill growth areas, and in existing residential brownfield site located adjacent to an existing communities it is policy to ensure that proper neighbourhood centre. community and neighbourhood facilities are provided in conjunction with, and as an integral The accompanying Urban Design Report component of, major new residential prepared by Reddy Architecture outlines the developments and proposed design principles which informed the scheme and renewal/redevelopment areas, in accordance compliance with the Design Manual. with the concept of sustainable urban villages outlined under Policy RES15
Policy CC9: It is Council policy to promote The proposed student development has a flexible sustainable approaches to the improvement of layout and based on future needs, units could be standards for habitable accommodation, by divided or re-arranged to create different clusters allowing dwellings to be flexible, accessible and or room sizes. The proposal incorporates the adaptable in their spatial layout and design. principles of Universal Design through-out the site and development scheme.
In addition, the internal amenities within the development could be divided, combined or altered to fit new purposes, depending on future needs.
Community Development
5.11 Table 4.2 sets out relevant county plan development management policies for community development and an evaluation of the proposed development.
Table 5.2 – Evaluation of the proposed development in terms of relevant Community Policies
Development Management Policy Evaluation
Policy ST4: It is Council policy to support The proposed development includes units which suitable access for people with disabilities, are suitable for mobility impaired persons, which including improvements to buildings, streets and allows for ease of access. Landscape design and public spaces. detailing of roads and footpaths provide for movement throughout the development by Policy SIC3: It is Council policy to promote and mobility impaired persons, in compliance with support universal design whereby all Building Regulations Part M. environments can be used to the greatest extent possible by all people, regardless of age, ability The proposed development will provide or disability. pedestrian and cycle routes throughout the site. Disabled car parking spaces and set down spaces are also provided within the development adjacent to access points to the building.
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Compliance with the principles is demonstrated within the accompanying reports prepared by Reddy Architecture. Policy SIC7: It is Council policy to ensure that The proposed development is located in close proper community infrastructure and proximity to a range of facilities, including UCD complementary neighbourhood facilities are and its clubs, libraries and gyms. A provided concurrently with the development of neighbourhood centre is located directly adjacent new residential growth nodes in the County. to the development including a bike repair shop, café and clothing shops.
The development itself also includes a range of internal and external amenity spaces such a study spaces, a café and a lounge.
Connectivity and Transport
5.12 Table 5.3 sets out relevant county plan development management policies for connectivity and transport and an evaluation of the proposed development which are addressed as relevant below;
Table 5.3– Evaluation of the proposed development in terms of relevant Transport Policies
Development Management Policy Evaluation
Policy ST2: It is Council policy to actively support The proposed development is located within a 14 sustainable modes of transport and ensure that minute walk of a Luas stop as well as within 10 land use and zoning are fully integrated with the metres from the no. 11 bus stop. Walking, public provision and development of high public quality transport and cycling is actively promoted within transportation systems. the scheme with 188 no. cycle parking spaces provided on site for both residents and visitors. This will also be promoted by the site management team through sustainable travel initiatives outlined in the accompanying Management Plan by Fresh Property Group. The site is within 800m of the UCD Belfield Campus and it is anticipated that students will walk or cycle to the university.
Policy ST6: The Council will continue to maintain We note that works are currently taking place and expand the footway and pedestrian route along the frontage of the site to upgrade the network to provide for accessible pedestrian existing cycle networks providing improved routes within the County in accordance with best connectivity to the site. The proposed accessibility practice. development will enhance the pedestrian route and public realm along its road frontage.
Given the nature of the works currently underway, the applicant is willing to accept a condition to upgrade the existing landscaping at the front boundary of the site in consultation with Dun Laoghaire Rathdown Council Parks Department.
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Sustainability
5.13 Table 5.4 sets out relevant county plan development management policies for sustainability and an evaluation of the proposed development.
Table 5.4– Evaluation of the proposed development in terms of relevant Sustainability Policies
Development Management Policy Evaluation
Policy EI1: It is Council policy to require that all An Appropriate Assessment screening has been developments relating to water supply and carried out by Openfield in relation to this waste water treatment are subject to screening development. The report states; for Appropriate Assessment to ensure there are no likely significant effects on the integrity, “Foul and surface drainage infrastructure will be defined by the structure and function, of any separated up to the final point of entry to the Natura 2000 sites and that the requirements of municipal sewer. Foul effluent from the proposed Article 6 of the EU Habitats Directive are met. development will be sent to the wastewater treatment plant at Ringsend in Dublin. Emissions from the plant are currently not in compliance with the Urban Wastewater Treatment Directive. In April 2019 Irish Water was granted planning permission to upgrade the Ringsend plant. This will see improved treatment standards and will increase network capacity by 50%, with a target completion date of 2022. There are no other discharges from this operation. The proposed project is not likely to significantly affect the volumes of wastewater generated.”
Policy EI3: It is Council policy to require that a SuDS has been applied to the proposed Sustainable Drainage System (SuDS) is applied development in order to ensure sufficient water to any development and that site specific drainage methods are in place. solutions to surface water drainage systems are developed, which meet the requirements of the A third party SUDS Audit was also undertaken as Water Framework Directive and the associated part of design development of the scheme and all River Basin Management Plans and ‘Water recommendations were discussed with Dun Quality in Ireland 2007-2009’ (EPA 2011) or any Laoghaire Council and agreed prior to lodgement. updated version of the document. Details are included within the Civil Engineering Infrastructure Design Report prepared by BMCE. Policy EI8: It is Council policy to ensure that all development proposals incorporate Sustainable Drainage Systems (SuDS).
Policy EI9: It is Council policy to ensure that all A Stormwater Impact Assessment has been new significant developments prepare a carried out by BMCE Engineers (see Section 2.3 Stormwater Impact Assessment which of the Infrastructure Design Report) in relation to incorporate Stormwater Audits in accordance this development, in accordance with the with the Council’s Stormwater Management Council’s Stormwater Management Plan Plan Guidance Document and the Council’s Guidance Document and the Council’s Development Management Thresholds Development Management Thresholds Information Document. Information Document.
Policy CC7: It is Council policy that all new The application is accompanied by an Energy buildings will be required to meet the passive and Sustainability Statement prepared by Ronan house standard or equivalent, where reasonably Meally Consulting Engineers which addresses practicable. By equivalent we mean approaches the requirements of Policy CC7. supported by robust evidence (such as
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monitoring studies) to demonstrate their efficacy, with particular regard to indoor air quality, energy performance, comfort, and the prevention of surface/interstitial condensation. Buildings specifically exempted from BER ratings as set out in S.I. .No 666 of 2006 are also exempted from the requirements of CC7. These requirements are in addition to the statutory requirement to comply fully with Parts A-M of Building Regulations.
Urban Design
5.14 Table 5.5 sets out relevant county plan development management policies for urban design and an evaluation of the proposed development in terms of each policy.
Table 5.5– Evaluation of the proposed development in terms of relevant Design Objectives
Development Management Policy Evaluation
Policy UD2: It is Council policy that, for all An Urban Design Report has been prepared by medium-to-large scale and complex planning Reddy Architecture and is submitted as part of applications (30 + residential units, commercial this application. In addition, the developments development over 1,000 sq.m. or as required by compliance with the Urban Design Manual has the Planning Authority) a ‘Design Statement’ been outlined in Section 4 above and within the shall be required to demonstrate how the Urban Design Report. proposed development addresses or responds to the design criteria set out in the ‘Urban Design Manual - A Best Practice Guide’ (DoEHLG, 2009).
Policy UCD3: It is Council policy that all The subject site has a 90m frontage to Goatstown development proposals, whether in established Road. The proposed development will enhance areas or in new growth nodes, should contribute the pedestrian route and public realm along its positively to an enhanced public realm and road frontage by re-establishing the building line should demonstrate that the highest quality in of the street and introducing planting. In addition, public realm design is achieved. the design of the building is high quality and attractive, complementing the established Policy UD5: It is Council policy to promote safer residential nature of the street and providing and more attractive streets and public realm for passive surveillance. all road users throughout the County by pro- actively engaging with, and adhering to, the As noted earlier, due to the ongoing upgrade ‘shared space’ concept and guidance set out in works outside the site, the applicant respectfully the ‘Design Manual for Urban Roads and requests a condition be included to provide Streets’ (2013). additional planting within the public domain should this be required by Dun Laoghaire Rathdown Council.
Policy UD6: It is Council policy to adhere to the The proposed development aligns with national recommendations and guidance set out within objectives on building height and density and the the Building Height Strategy for the County. heights of the surrounding developments as discussed earlier in this report. A Statement of Material Contravention accompanies this application in this respect.
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Goatstown Local Area Plan 2012 (as extended)
Land Use Zoning
5.15 The overall subject lands are zoned, Objective A, ‘to protect and improve residential amenity’. There are no specific objectives included relevant to the subject site however a Quality Bus Priority Route is proposed to the west of the site along Goatstown Road.
Figure 8 – Land Use Zoning
5.16 Chapter 2 of the Dun Laoghaire Rathdown County Development Plan (CDP) sets out the objectives for residential development in the local area. Specifically, the CDP states that; ‘demand for student accommodation in the County is significant and has to be addressed’. RES12 states;
‘It is Council policy to facilitate student accommodation on student campuses or in locations which have convenient access to Third Level colleges (particularly by foot, bicycle and high quality and convenient public transport) in a manner compatible with surrounding residential amenities. In considering planning applications for student accommodation the Council will have regard to the ‘Guidelines on Residential Developments for Third Level Students’ and its July 2005 Review (particularly in relation to location and design).’
5.17 The proposed development will provide high-quality purpose-built student accommodation (PBSA) to address demand in the area. It is apparent that the CDP acknowledges that the provision of student accommodation developments in the area are an important component of the housing strategy for the county. The provision of purpose-built student accommodation can have a significant benefit for housing availability, releasing existing housing stock occupied by students.
5.18 Section 8.2.3 – Residential Development of the CDP outlines the development management standards for residential schemes. Specifically, (xii) sets out the requirements for student accommodation. The CDP notes that;
‘The Council will support the provision of on-campus accommodation and may also permit student accommodation off-campus.’
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5.19 It is also noted that the location of student accommodation will be prioritised under the following hierarchy;
▪ On Campus; ▪ Within 1km distance from the boundary of a Third Level Institute; ▪ Within close proximity to high quality public transport corridors (DART, N11 and Luas), cycle and pedestrian routes and green routes.
Response: As demonstrated on the Mobility Map prepared by Reddy Architecture and contained in the Urban Design Report the subject site is located within 800m or the equivalent of a 13minute walk (6 minute cycle) of the UCD campus. A cycle lane (which is currently being upgraded by the Council) directly connects the site and UCD campus. The site is also served by the 11 bus which stops almost directly in front of the site at Trimbleston. This connects the site to the city centre, as well as St Patricks College Drumcondra, and DCU. On average, the bus generally services the stop every 15-20 minutes. The site therefore meets the above criteria.
5.20 The following assessment criteria is set out within the CDP and has been addressed as follows;
▪ The potential impact on residential amenities. Full cognisance will be taken of the need to protect existing residential amenities particularly in applications for larger scale student accommodation, and such accommodation will not be permitted where it would have a detrimental effect.
Response: The proposed development has been designed to mitigate any overlooking of existing adjoining residential properties through the use of off-set angled windows, blank facades and separation distances. The proposed scale of the scheme is reflective of the existing built form, with the highest points of the building contained to the northern section of the site, providing a natural transition in scale from the 5-storey elements of Trimbleston to the existing 2-storey neighbourhood centre to the south.
This application is accompanied by a Management Plan prepared by Fresh Property Group, an experienced provider who currently manage 59 no. student accommodation sites throughout the UK and Ireland. This demonstrated experience and policies developed over a number of years will ensure the professional and orderly management and use of the development by the resident students.
▪ The level and quality of on-site facilities, including storage facilities, waste management, covered cycle parking and associated showers and locker, leisure facilities, car parking and amenity.
Response: 507 sqm of internal student amenity space and 1,554sqm of external amenity space has been provided within the proposed development (total 2,061sqm). The internal amenity space includes student lounge areas with a shared kitchen/tearoom, multi-purpose spaces and a laundry and is further detailed in the HQA prepared by Reddy Architects.
These areas are located on the ground floor of the scheme directly fronting Goatstown Road, providing a level of activation to the frontage. This also allows for the provision of bedrooms at quieter areas of the site. The proposed internal amenity spaces are also directly accessible via the external courtyard area provided to the rear of the development. Roof top gardens are also provided on the southern and western elevations providing amenity areas for students.
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▪ The architectural quality of the design and also the external layout, with respect to materials, scale, height and relationship to adjacent structures. Internal layouts should take cognisance of the need for flexibility for future possible changes of use.
Response: An Urban Design Report including a schedule of materials accompanies this application. CGIS and a Townscape and Visual Impact Assessment also accompany the proposal.
The scheme will fully integrate with the existing neighbourhood whilst also acknowledging the objectives of the Goatstown LAP and the desired future out outcome for the site. Flexibility has been incorporated into the layout to accommodate future uses should this be required.
▪ The number of existing similar facilities in the area. In assessing a proposal for student accommodation the planning authority will take cognisance of the amount of student accommodation which exists in the locality and will resist the over- concentration of such schemes in any one area in the interests of sustainable development and residential amenity.
Response: A review of the local area (see map below) has revealed one purpose built student accommodation development in the immediate area, outside of the UCD campus. Glenard University Residence located at no. 36 Roebuck Road, Clonskeagh includes c. 30 bed spaces and is an initiative of Opus Dei, accommodating female students only.
The proposed development will add to the stock of student bed-spaces in Dublin and respond to meeting an identified need for high quality and effectively managed accommodation in line with the CDP.
The proposed development has been designed in accordance with Section 8.2.3 of the CDP which provides guidelines for student accommodation developments.
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5.21 In absence of recent national policy guidance (noting compliance with the 1999 Guidelines under the Finance Act have been addressed with the Opinion Response document prepared by Reddy Architecture and John Spain Associates), Section 16.10.7 of the Dublin City Development Plan 2016-2022 has been used to provide design guidance for the subject student accommodation development as follows:
▪ The student accommodation should be designed to give optimum orientation in terms of daylight to habitable rooms. Given the nature of student occupancy, the residential standards in relation to dual aspect and north facing units may be relaxed, subject to compliance with the principles of Site Layout Planning for Daylight and Sunlight, A guide to good practice (Building Research Establishment Report, 2011)
Response: The application is accompanied by a Sunlight and Daylight analysis report prepared by Digital Dimensions and demonstrates full compliance with the above.
▪ Adequate open space of suitable orientation should be provided within developments for the amenity of students, which can include terraces, courtyards and roof gardens, where appropriate. All proposals must provide appropriate indoor and outdoor communal and recreational facilities for students at a combined level of at least 5-7 sqm per bed-space
Response: Amenity space in excess of 6sqm has been provided throughout the scheme. 507 sqm indoor amenity space and 1,554sqm of external amenity space has been provided as detailed earlier.
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▪ Student accommodation shall contain a maximum of 40% single/double occupancy units with a minimum gross floor area of 25 sqm and a maximum gross floor area of 35 sqm
▪ Study bedrooms shall share a common entrance hall and kitchen/living room. In addition, “house” units shall share common entrances, access stairs, corridors and ancillary facilities
▪ A shared kitchen/living/dining room shall be provided, based on a minimum 4 sqm per bed-space in the unit, in addition to any circulation space.
▪ Bedrooms: Single study bedroom: 8 sq. m (with en suite shower, toilet and basin: 12 sqm).
▪ Single disabled study bedroom, with en suite disabled shower, toilet and basin: 15 sqm).
▪ Bathrooms: Either en suite with study bedrooms or to serve a maximum of 3 bed-spaces.
▪ Communal facilities and services which serve the needs of students shall be provided for, which include laundry facilities, caretaker/ security office and refuse facilities.
Response: The proposals meet each of the above criteria, as noted by the architectural drawings and Housing Quality Assessment prepared by Reddy Architects which accompanies this submission.
Table 5.6 – Evaluation of the proposed development in terms of the LAP’s relevant objectives for population and housing
Population and Housing Objectives Evaluation
RD1: It is an objective of the Plan that all new The proposal provides a range of student residential development within the Plan area accommodation varieties from studio to 5-8 no. shall provide for a mix of household types, sizes units in clusters. and tenures that both complements and enhances the existing residential mix.
RD2: It is an objective of the Plan that new The developments compliance with the Urban residential development shall comply with the Design manual has been outlined in the Guidelines for Sustainable Residential preceding sections and within the Guidelines for Development in Urban Areas and accompanying Sustainable Residential Development in Urban Urban Design Manual (May 2009). Areas in 3.6.
Sustainability
5.22 Table 4.7 provides an evaluation of the subject lands in relation to sustainability.
Table 5.7– Evaluation of the proposed development in terms of the LAP’s overall Sustainability
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Sustainability Evaluation
OS3: It is an objective of the Plan to protect and The subject site as existing does not contain any enhance biodiversity within the Plan area in green spaces or planting. The proposed accordance with the Green City Guidelines. development would reintroduce these elements to the site through planting and roof gardens as illustrated in the accompanying landscape drawings by RMDA.
WD2: It is an objective of the Plan to ensure that SuDS has been applied to the proposed all development proposals incorporate development in order to ensure sufficient water appropriate Sustainable Drainage Systems drainage methods are in place. Green roofs have (SuDS) been incorporated where possible throughout the scheme.
Transport and Services Infrastructure
5.23 Table 5.8 sets out relevant LAP objectives for transport and service infrastructure and an evaluation of the proposed development in terms of each objective.
Table 5.8– Evaluation of the proposed development in terms of the LAP’s overall Transport and Service Infrastructure
Transport and Services Infrastructure Evaluation
MT4: It is an objective of the Plan to encourage The proposed development is located within a 14 and prioritise sustainable modes of transport minute walk of a green line Luas stop and a 13 including walking, cycling and public transport minute walk to UCD Campus. The site is also and reduce reliance on the use of private cars. within 1.3km of Dundrum town centre. Walking, public transport and cycling are promoted by the MT6: It is an objective of the Plan to ensure that management team of the scheme as the all new development within the Plan area helps preferred method of travel for residents. A Travel promote an improved permeable urban Plan is included in the management plan in this environment and maximises opportunities to respect. 188 no. secure cycle parking spaces are provide direct pedestrian and cycle links both provided within the scheme. within the Plan area itself and with the immediate environs. A specific objective is to investigate the Secure and sheltered cycle parking has also possibility of improving cycle/pedestrian access been provided within the developments. from Goatstown to UCD via the Knockrabo sites.
MT7: It is an objective of the Plan that all new Due to the developments proximity to UCD development will provide car parking in campus and to a range of facilities and public accordance with the minimum and maximum transport, the number of car parking spaces has standards set out in the County Development been greatly reduced in order to prioritise Plan. walking, public transport and cycling. A nominal provision of 6 spaces have been provided onsite including 4 no. set down spaces adjacent to the entrance to the building and frontage of the site. 2 no. disabled parking spaces have also been provided within easy access of the building entrance. The remainder of the site is pedestrian focused with pathways and paving throughout the site to increase permeability and encourage pedestrian activity. A detailed justification for the proposed parking provision is included in the Civil
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Transport and Services Infrastructure Evaluation
Engineering Infrastructure Report prepared by BMCE.
MT9: It is an objective of the Plan that all new Sheltered and secure cycle parking has been residential and commercial development provided throughout this development in schemes must include adequate provisions for accordance with CDP standards. 188 no. bicycle safe and secure cycle parking facilities at spaces have been provided with visitor spaces appropriate locations in accordance with County located adjacent to the front boundary in the form Development Plan standards of Sheffield stands an stacked parking provided within the internal courtyard for residents.
Urban Design
5.24 Table 5.9 sets out relevant LAP objectives for urban design and an evaluation of the proposed development in terms of each objective.
Table 5.9– Evaluation of the proposed development in terms of the LAP’s relevant objectives for urban design
Urban Design Evaluation
UD1: It is an objective of the Plan that new The proposed development re-establishes the development within Goatstown shall be of a high building line of the streetscape, improving the quality design and layout that makes a positive public realm and enforcing the relationship contribution to the local built environment and between the development and its surroundings. enhances the identity and sense of place of the Plan area and its environs. In addition, the height of the development is reduced towards the south where there are UD8: It is an objective of the Plan to improve the existing residential dwellings and a appearance, quality and overall function of the neighbourhood centre. public realm within the Plan area The overall layout of the design has been centred UD9: It is an objective of the Plan to require around an internal courtyard; this reduces applications for multiple residential / mixed-use overlooking onto adjacent sites while still allowing development to clearly demonstrate the for passive surveillance of the courtyard and the measures proposed to enhance the public road frontage. realm.
UD2: It is an objective of the Plan that all new In addition, the developments compliance with residential and mixed-use development shall be the Urban Design manual has been outlined in designed having regard to the 12 design criteria the preceding Section 4 of this report above. set out in the Urban Design Manual (DoEHLG May 2009).
UD3: It is an objective of the Plan that any An Urban Design Report has been prepared by planning applications for the redevelopment Reddy Architects and submitted as part of this opportunity sites identified on Map 3 shall application. include a design statement that sets out the overall design, context and aims of the proposal.
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Urban Design Evaluation
UD5: It is an objective of the Plan that height in The proposed development accords with the excess of two-storeys shall only be permitted Guidelines for Planning Authorities on where it is considered by the Planning Authority Sustainable Residential Development in Urban that the proposed development can be easily Areas (2009) and could be best described as a absorbed into the existing urban landscape and large infill site, having regard to an existing will not be visually obtrusive or overbearing. residential development to the north and east of the site, Trimbleston. This development is UD6: It is an objective of the Plan that a comprised of housing and apartments which benchmark height of three storeys (with a range from 5 storeys to 2-3 storeys (to the east). possible additional set back floor or occupied The proposed development is in keeping with this roof space) shall apply on the sites of the Goat density and style of stepping down development. Public House, Topaz garage and adjoining retail In addition, the height of the development is units and the former Victor Motors site. Height reduced towards the south. should graduate down to a maximum of two- storey along the site boundaries where they adjoin existing low-rise development.
UD7: It is an objective of the Plan to promote the efficient use of land by facilitating higher densities within the Plan area in accordance with County Development Plan policy.
Evaluation of Consistency
5.25 Having regard to the evaluation contained within the tables above, the proposed development is considered to be consistent with the relevant LAP objectives.
The Victor Motors Site Strategy:
5.26 The site is highlighted within the LAP as one of five locations including a ‘site framework strategies.’ This strategy provides the subject site with a proposed, but not definitive, development solution and demonstrates the suitability of the site for redevelopment. The aspects of this development solution framework have been assessed in relation to the proposed development below:
• Zoning: To protect and/or improve residential amenity.
Response: The proposed development provides student housing (residential) that is both respectful of the surrounding developments, in terms of streetscape, building line, privacy and building heights, and provides much needed accommodation in an infill area, close to UCD.
• Height: A benchmark of three storeys, with possible setback floor or occupied roof space.
Response: The proposed development is 4 to 6 no. storeys in height. While this is not strictly in line with the height objective for the site, it accords with the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), having regard to an existing residential development to the north and east of the site,
John Spain Associates Planning & Development Consultants 48 September 2020 Statement of Consistency
Trimbleston. We also note recent development at The Grove to the north of the site which includes 5 no. storey residential development. The proposed development is in keeping with this density and style of stepping down development and the emerging built form of the area. In addition, the height of the development is reduced towards the south of the site. A detailed response in this regard is included in the accompanying Statement of Material Contravention by John Spain Associates. A Townscape and Visual Impact Assessment prepared by Parkhood assess the scale of the proposal in terms of the surrounding area and concludes;
‘The Application Site comprises a commercial site that contributes little to the character and visual quality of this part of Dublin. The proposed development, while more substantial, would result in a positive contribution to the townscape character and urban fabric of Goatstown. While recognising there are some significant local impacts, this report concludes that this proposal, on balance, has no unacceptable townscape / landscape or visual effects and can be successfully absorbed into the character and views of this part of the city.’
• Design: High quality, positive contribution to the streetspace, harmonise with neighbouring developments, continues the building line, consideration of ESB substations and bin storage locations.
Response: The proposed development is a high-quality design, which re-establishes the building line and improves the streetscape. The design is respectful of the surrounding heights of the developments to the north, east and south. In addition, the substations, bin storage and cycling parking have been carefully considered within the layout and are screened with planting. A detailed design rationale is included in the Urban Design Statement by Reddy Architects.
• Movement: Facilitate permeability, cycle parking provided and car parking to be underground.
Response: A Mobility Map has been prepared by Reddy Architecture and includes an assessment of the walking and cycling times from the site to UCD. The map shows that the site is within 13 minutes walking distance and within a 6 minute cycle from UCD via the Roebuck entrance to the university. We note that there is a cycle lane along the entire route from the site to UCD there by encouraging safe cycling access to the university.
The site is also within a 13 minute walk and a 5 minute cycle of Dundrum Luas Stop. This also provides access to a huge number of shopping facilities, amenities and services within Dundrum town centre.
John Spain Associates Planning & Development Consultants 49 September 2020 Statement of Consistency
The mobility map demonstrates that the site is suitability located to accommodate a purpose-built student accommodation scheme in close proximity to Ireland’s second largest university.
The development guidance section of the Goatstown LAP notes that site permeability should be considered in relation to the subject site. We note that the rear of the site directly adjoins the rear of the Trimbleston Scheme, which is a well-established residential scheme and no opportunity is available to connect to the scheme in this regard.
Mature landscaping frames the rear of the development within the Trimbleston scheme which is privately owned. There is no opportunity available for a new pedestrian connection between the proposed scheme and the existing development.
A pedestrian connection would impact on the privacy and amenity of the private common area to the rear of the Trimbleston scheme, currently enjoyed by its residents. Further, a pedestrian connection would not offer a valuable connection to the proposed scheme or Goatstown Road due to the private nature of the landholdings to the rear of the site. There is no existing connection point available to UCD via existing residential areas to the rear of the scheme, all are private landholdings.
It is further noted that the applicant has no control or right of way over the adjoining lane to the south of the site which is utilised by the neighbourhood centre. The nature of the lane (length and orientation) is also considered unsuitable for student use, particularly at night
• Landscaping: High quality public and private open space with no unduly overshadowing and tree planning along site frontage.
Response: Hight quality open space has been included within the development as sizeable roof gardens and a central courtyard. This will include planting which reintroduces greenery to the subject site as detailed in the accompanying plans prepared by Ronan MacDiarmada Landscape Architects.
6.0 CONCLUSIONS
6.1 The statement set out herein demonstrates the consistency of the proposed development with the relevant national, regional and local planning policy context. At a national and regional level, this statement has demonstrated the consistency of the development with the following:
• National Planning Framework; • Regional Economic and Spatial Strategy for the East and Midlands Region 2019- 2031; • Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), and the accompanying Urban Design Manual; • Urban Development and Building Height Guidelines (December 2018);
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• Delivering Homes, Sustaining Communities (2008) and the accompanying Best Practice Guidelines- Quality Housing for Sustainable Communities; • Smarter Travel – A New Transport Policy for Ireland (2009-2020); • The Planning System and Flood Risk Management (2009); • Guidelines on Residential Developments for 3rd Level Students (2005); • Draft Water Services Guidelines for Planning Authorities (2018); • National Student Accommodation Strategy – Rebuilding Ireland (2017).
6.2 Consistency is also demonstrated with the policies and provisions of the Dun Laoghaire Rathdown County Development Plan and the Goatstown Local Area Plan 2012 (as extended), which are the key planning policy documents at a local level.
6.3 UCD is the second largest university in Ireland; with 33,285 students studying on its 133- hectare grounds. Students attend from all over the country and abroad as UCD is ranked within the top 1% of higher education institutions international.
6.4 The percentage of students living in rented private accommodation has been declining from 37% in 2013 to 23% in 2016 and this is a direct attribute of schemes such as the proposed development.
6.5 The subject site is located within 800m or the equivalent of a 13minute walk (6 minute cycle) of the UCD campus. A cycle lane directly connects the site and UCD campus. The site is also served by the 11 bus which stops almost directly in front of the site at Trimbleston. This connects the site to the city centre, as well as St Patricks College Drumcondra, and DCU. On average, the bus generally services the stop every 20 minutes.
6.6 It is respectfully submitted that the proposed development will provide an appropriate form of high-quality student accommodations on the subject lands.
6.7 The proposed development and accompanying documentation and reports have been prepared following extensive pre-planning consultation with Dun Laoghaire Rathdown County Council as detailed above which forms a part of this application for pre- application consultation with An Bord Pleanála.
6.8 In conclusion, it is respectfully submitted that the proposed development is consistent with and in accordance with the proper planning and sustainable development of the area, and complies with all relevant national, regional and local planning policies and guidelines and that the proposal as presented constitutes a reasonable basis for an application.
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Appendix 1
Dun Laoghaire Rathdown County Development Plan 2016-2022
Housing
Policy RES2: It is Council policy to facilitate the implementation and delivery of the Interim Housing Strategy 2016 – 2022.
Policy RES3: It is Council policy to promote higher residential densities provided that proposals ensure a balance between the reasonable protection of existing residential amenities and the established character of areas, with the need to provide for sustainable residential development. In promoting more compact, good quality, higher density forms of residential development it is Council policy to have regard to the policies and objectives contained in the following Guidelines: • ‘Sustainable Residential Development in Urban Areas’ (DoEHLG 2009).
• ‘Urban Design Manual - A Best Practice Guide’ (DoEHLG 2009).
• ‘Quality Housing for Sustainable Communities’ (DoEHLG 2007).
• ‘Irish Design Manual for Urban Roads and Streets’ (DTTaS and DoECLG, 2013).
• ‘National Climate Change Adaptation Framework - Building Resilience to Climate Change’ (DoECLG, 2013).
Policy RES4: It is Council policy to improve and conserve housing stock of the County, to densify existing built-up areas, having due regard to the amenities of existing established residential communities and to retain and improve residential amenities in established residential communities.
Policy RES12: It is Council policy to facilitate student accommodation on student campuses or in locations which have convenient access to Third Level colleges (particularly by foot, bicycle and high quality and convenient public transport) in a manner compatible with surrounding residential amenities. In considering planning applications for student accommodation the Council will have regard to the ‘Guidelines on Residential Developments for Third Level Students’ and its July 2005 Review (particularly in relation to location and design).
Policy RES14: It is Council policy to plan for communities in accordance with the aims, objectives and principles of ‘Sustainable Residential Development in Urban Areas’ and the accompanying ‘Urban Design Manual – A Best Practice Guide’. In all new development growth areas, and in existing residential communities it is policy to ensure that proper community and neighbourhood facilities are provided in conjunction with, and as an integral component of, major new residential developments and proposed renewal/redevelopment areas, in accordance with the concept of sustainable urban villages outlined under Policy RES15.
Policy CC9: It is Council policy to promote sustainable approaches to the improvement of standards for habitable accommodation, by allowing dwellings to be flexible, accessible and adaptable in their spatial layout and design.
Design
Policy UD2: It is Council policy that, for all medium-to-large scale and complex planning applications (30 + residential units, commercial development over 1,000 sq.m. or as required
John Spain Associates Planning & Development Consultants September 2020 Statement of Consistency by the Planning Authority) a ‘Design Statement’ shall be required to demonstrate how the proposed development addresses or responds to the design criteria set out in the ‘Urban Design Manual - A Best Practice Guide’ (DoEHLG, 2009).
Policy UCD3: It is Council policy that all development proposals, whether in established areas or in new growth nodes, should contribute positively to an enhanced public realm and should demonstrate that the highest quality in public realm design is achieved.
Policy UD5: It is Council policy to promote safer and more attractive streets and public realm for all road users throughout the County by pro-actively engaging with, and adhering to, the ‘shared space’ concept and guidance set out in the ‘Design Manual for Urban Roads and Streets’ (2013).
Policy UD6: It is Council policy to adhere to the recommendations and guidance set out within the Building Height Strategy for the County.
Sustainability
Policy EI1: It is Council policy to require that all developments relating to water supply and waste water treatment are subject to screening for Appropriate Assessment to ensure there are no likely significant effects on the integrity, defined by the structure and function, of any Natura 2000 sites and that the requirements of Article 6 of the EU Habitats Directive are met.
Policy EI3: It is Council policy to require that a Sustainable Drainage System (SuDS) is applied to any development and that site specific solutions to surface water drainage systems are developed, which meet the requirements of the Water Framework Directive and the associated River Basin Management Plans and ‘Water Quality in Ireland 2007-2009’ (EPA 2011) or any updated version of the document.
Policy EI8: It is Council policy to ensure that all development proposals incorporate Sustainable Drainage Systems (SuDS)
Policy EI9: It is Council policy to ensure that all new significant developments prepare a Stormwater Impact Assessment which incorporate Stormwater Audits in accordance with the Council’s Stormwater Management Plan Guidance Document and the Council’s Development Management Thresholds Information Document.
Policy CC7: It is Council policy that all new buildings will be required to meet the passive house standard or equivalent, where reasonably practicable. By equivalent we mean approaches supported by robust evidence (such as monitoring studies) to demonstrate their efficacy, with particular regard to indoor air quality, energy performance, comfort, and the prevention of surface/interstitial condensation. Buildings specifically exempted from BER ratings as set out in S.I. .No 666 of 2006 are also exempted from the requirements of CC7. These requirements are in addition to the statutory requirement to comply fully with Parts A-M of Building Regulations.
Transport
Policy ST2: It is Council policy to actively support sustainable modes of transport and ensure that land use and zoning are fully integrated with the provision and development of high public quality transportation systems.
Policy ST6: The Council will continue to maintain and expand the footway and pedestrian route network to provide for accessible pedestrian routes within the County in accordance with best accessibility practice.
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Policy ST20: It is Council policy to require the submission of Travel Plans for developments that generate significant trip demand. Plans should seek to reduce reliance on car based travel and encourage more sustainable modes of transportation over the lifetime of a development.
Community Infrastructure
Policy ST4: It is Council policy to support suitable access for people with disabilities, including improvements to buildings, streets and public spaces.
Policy SIC3: It is Council policy to promote and support universal design whereby all environments can be used to the greatest extent possible by all people, regardless of age, ability or disability.
Policy SIC7: It is Council policy to ensure that proper community infrastructure and complementary neighbourhood facilities are provided concurrently with the development of new residential growth nodes in the County.
John Spain Associates Planning & Development Consultants September 2020 Statement of Consistency
APPENDIX 2 – PRE-APPLICATION DISCUSSIONS (UNDER S. 247 OF ACT)
Dun Laoghaire Rathdown County Council (DLR) - Section 247 Meeting
DLR Section 247 Meeting – 31st October 2019
Attendees
Dun Laoghaire Council Attendees Ger Ryan (Senior Exec. Planner) Shane Sheady (Senior Exec. Planner) Eoin Kelliher (Executive Planner) Bernard Egan – Senior Executive Engineer – Drainage Planning Section Elaine B. Carroll – Executive Engineer – Drainage Planning Section Claire Casey – Senior Executive Engineer – Transportation Planning Section List of Attendees for Orchid Residential Ltd Charlie O’ Reilly Hyland (Orchid Residential) Rob Keane (Reddy Architecture) Peter O’ Dwyer (BM Consulting Engineers) John Spain (John Spain Associates) Meadhbh Nolan (John Spain Associates)
Summary of the Matters Discussed
An overview of the PBSA scheme and its context in proximity to UCD.
DLR requested a context plan, demonstrating the sites proximity to UCD and the modes of travel available to the different entrance points to UCD.
It was agreed that the permeability objective of the site in the LAP is vague and would not provide a valuable connection on the subject site given the established private residents adjoining the site.
DLR commented on the treatment of the front elevation of the development in terms of the length of the built form and the landscape treatment.
DLR noted that they were not averse to encroachment into the front setback as noted in the LAP.
DLR noted that Part V compliance may be sought within the scheme. The applicant noted the Board’s clear decision on the Blakes and Esmonde Motors site (ABP-300520) where the decision was made that Part V is not applicable to student accommodation schemes.
The applicant put forward that given the proximity to UCD and the need to instigate a modal change, limited parking has been provided onsite. Cycling parking is required to be provided as per the development plan.
Drainage and IW requirement for the upgrade of the current system on Goatstown Road was discussed.
DLR Section 247 Meeting
John Spain Associates Planning & Development Consultants September 2020 Statement of Consistency
14th January 2020
Attendees
Ger Ryan (Senior Exec. Planner) Shane Sheady (Senior Exec. Planner) Eoin Kelliher (Executive Planner) Bernard Egan – Senior Executive Engineer – Drainage Planning Section Claire Casey – Senior Executive Engineer – Transportation Planning Section Dara O’ Daly – Landscape Architect (Parks Team) Charlie O’ Reilly Hyland (Orchid Residential) Max O’Reilly Hyland (Orchid Residential) Lisa Wynne (Reddy Architecture) Brian Mahony (BM Consulting Engineers) Meadhbh Nolan (John Spain Associates)
Matters Discussed
Drainage DLR noted that compliance was being achieved on the site and in principle agreed with the scheme as proposed.
Parking DLR maintain their concerns with the nominal parking provision proposed at the site.
Landscaping Further detail on the interface of the front of the site and the public realm was sought. Part M compliance is to be achieved. Further detail design of the internal courtyard space, its use and suitable planting was requested.
Further detail and design of the roof top gardens was also sought.
Design and Height Contextual analysis is required to justify the height in relation to the surrounding existing built form.
The setback top floor on the adjoining Trimbleston development was noted by DLR and suggested this is considered for the subject scheme.
Contextual sections and elevations were requested.
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